The FSC Supervisory Cycle 2024/25 reported a post-onsite inspection compliance rate of only 61% for the Independent Audit function of Management Companies.
Independent audit is not simply an annual exercise to be completed. Its value lies in providing an objective assessment of whether an organisation’s AML/CFT framework is adequately designed, properly implemented and working in practice.
A meaningful independent audit should do more than confirm that policies, procedures and controls exist. It should test them, challenge them and identify where practice does not match what is documented.
And perhaps most importantly, the value of an audit does not end when the report is issued. Findings need to translate into clear remediation, ownership and follow-up.
The question is therefore not only: “Have we completed our independent audit?”
It is: “What did our independent audit tell us — and what did we do about it?”
Navigating Compliance. Managing Risk. Differently
