The annual file review plan was approved. The methodology was agreed. The target was clear.
Then came onboarding, regulatory requests, remediation exercises, audits, transaction alerts and the day-to-day demands on the Compliance team.
And the file reviews started falling behind.
This is a challenge we regularly see. The issue is not always the absence of a review framework — often, it is simply capacity and competing priorities.
Acrion can provide independent file review support to help organisations execute their planned reviews, address backlogs or undertake targeted reviews of particular client populations.
But our approach goes beyond completing a checklist.
We look at what the file actually tells us: whether the risk assessment makes sense, whether CDD and EDD are proportionate to that risk, whether source of funds/source of wealth is adequately understood and evidenced, whether screening has been properly addressed, and whether ongoing monitoring reflects the nature of the relationship.
More importantly, recurring issues across individual files can tell management something about the wider compliance framework.
A file review should not simply close a file on the review plan. It should tell you whether your controls are working in practice.
Need additional capacity to get your file review programme back on track?
Acrion can work alongside your Compliance team — independently, practically and at a scale that fits your requirements.
Navigating Compliance. Managing Risk. Differently
