🔎 A client file can contain every document on your checklist and still tell an outdated story.
A shareholder changes. Payments start arriving from a new country. Transaction values increase. The business moves into a different activity.
Does the file reflect those changes—and have their implications been assessed?
An effective file review connects the information you hold with what the client is doing today. It checks whether:
✅ Ownership and control information remains accurate.
✅ Activity and funding are consistent with your understanding of the client.
✅ The risk rating and due diligence remain appropriate.
✅ Gaps, follow-up actions and decisions are properly documented.
In Mauritius, regulation 3(1)(e) of the FIAML Regulations 2018 requires ongoing monitoring and the review of CDD records to keep information up to date and relevant, particularly for higher-risk customers.
At Acrion, we support compliance teams with independent file reviews, targeted assessments and review backlogs. We examine the evidence, highlight gaps and help prioritise practical remediation—including recurring issues that may need attention across your wider client portfolio.
Before marking a file “reviewed”, ask: does it still explain who the client is, what they do and why their activity makes sense?
📩 info@acrioncompliance.com
Navigating Compliance. Managing Risk. Differently
