AML/CFT Governance
- Board oversight
- MLRO / Compliance Officer arrangements
- Policies and procedures
- Governance structures
- Reporting and escalation
WM Advisory Group Ltd · UK · GCC · International
Independent AML/CFT Review & Compliance Testing
Independent, risk-based assessment of AML/CFT frameworks, controls and operational effectiveness for fintechs, financial-services businesses and regulated organisations.
Risk-based, evidence-led assessment of AML/CFT frameworks, policies, procedures and control effectiveness — tailored to the applicable regulatory framework and the requirements of the client, regulator, counterparty or contracting organisation.
Network affiliation
Why independent testing matters
Frameworks can look complete on paper. Controls must work in practice.
An AML framework can appear comprehensive in documentation while weaknesses remain in implementation — customer due diligence, transaction monitoring, sanctions screening, escalation, record keeping or governance. Independent testing helps management and boards identify those gaps.
A structured, evidence-led review assesses whether controls are operating as intended and establishes a documented remediation plan. Scope, methodology and reporting are tailored to the applicable regulatory framework and the requirements of the client, regulator, counterparty or contracting organisation.
Who we support
- Fintech companies
- Payment institutions
- Electronic money institutions
- Payment service providers
- Financial-services businesses
- Lending and financing platforms
- Payment aggregators
- Fintech supply-chain partners
- Regulated professional firms
- Higher-risk businesses
- Businesses preparing for regulatory or compliance reviews
- Companies requiring independent validation of AML/CFT controls
- Businesses requiring remediation validation following an AML review
What we review
Twelve areas of AML/CFT control assessment
Business-Wide / Enterprise-Wide Risk Assessment
- Customer risk
- Product risk
- Geographic risk
- Delivery-channel risk
- Risk-rating methodology
- Risk appetite
Customer Due Diligence / KYC
- Customer identification
- Verification
- Beneficial ownership
- Customer risk classification
- Ongoing monitoring
Enhanced Due Diligence
- High-risk customers
- PEPs
- High-risk jurisdictions
- Complex ownership structures
- Source of funds / source of wealth where applicable
Sanctions Screening
- Screening controls
- Screening configuration
- Alert handling
- Escalation
- False-positive management
- Evidence and audit trail
Transaction Monitoring
- Monitoring methodology
- Risk-based scenarios
- Alert generation
- Investigation procedures
- Escalation
- Case management
- Management information
Suspicious Activity Reporting
- Internal escalation
- Investigation
- Decision-making
- Reporting processes
- Record keeping
AML Training
- Staff training
- Role-specific training
- Training frequency
- Training records
- Awareness
Record Keeping
- CDD records
- Transaction records
- AML decisions
- Investigation records
- Retention controls
Outsourced AML / Third-Party Controls
- Outsourced KYC
- Screening providers
- Transaction monitoring providers
- Third-party reliance
- Vendor oversight
AML Technology & Systems
- KYC platforms
- Screening systems
- Transaction monitoring
- Case management
- Data quality
- Management information
Remediation Validation
- Review of previous findings
- Testing of corrective actions
- Evidence-based validation
- Closure assessment
Our AML review approach
A five-step, evidence-led process
- 01
Scoping & Regulatory Mapping
Understand the organisation, business model, regulatory environment and engagement objectives.
- 02
Documentation Review
Review policies, procedures, risk assessments, governance documents and relevant control documentation.
- 03
Control Testing
Test selected controls through evidence review, walkthroughs, sample testing and other procedures appropriate to the engagement.
- 04
Findings & Risk Rating
Identify weaknesses and classify findings according to agreed risk criteria such as Critical, High, Medium or Low.
- 05
Reporting & Remediation
Provide an independent report with observations, recommendations, management responses and remediation priorities.
Possible engagement types
Structured to the engagement terms
AML Health Check
For businesses seeking an independent high-level assessment of their AML/CFT framework.
Independent AML/CFT Effectiveness Review
Detailed review of the design and operating effectiveness of selected AML/CFT controls.
AML/CFT Agreed-Upon Procedures
A clearly defined factual findings engagement where procedures and reporting are agreed in advance with the client or intended users.
AML Remediation Validation
Independent testing of whether previously identified AML weaknesses have been appropriately remediated.
The precise engagement type, procedures, conclusion and wording depend on the engagement terms, applicable professional standards, regulatory requirements and intended users of the report.
UK & GCC experience
Cross-border awareness of applicable frameworks
WM Advisory Group can support organisations operating across the UK and GCC, with consideration of applicable local regulatory requirements. Regulatory applicability is determined by the client's specific licence, business model, jurisdiction and regulator. WM Advisory Group is not FCA-approved, CBUAE-approved, DFSA-approved, FSRA-approved or approved by any regulator unless such approval is specifically obtained.
United Kingdom
- UK Money Laundering Regulations
- FCA regulatory expectations where applicable
- JMLSG guidance where applicable
- Relevant sector-specific requirements
UAE / GCC
- UAE AML/CFT framework
- Applicable Central Bank requirements
- Applicable free-zone financial regulator requirements
- DFSA requirements where applicable
- FSRA requirements where applicable
- Other applicable local requirements
What clients receive
Clear, evidence-based reporting
Our reports are designed to provide clear, evidence-based documentation that can support management, board, compliance, due-diligence and regulatory processes, subject to the requirements of the relevant organisation or regulator.
- 01Executive summary
- 02Scope and methodology
- 03Regulatory framework considered
- 04Control assessment
- 05Sample-testing observations where applicable
- 06Risk-rated findings
- 07Root-cause observations where appropriate
- 08Recommendations
- 09Management action plan
- 10Priority remediation areas
- 11Final independent report
Who benefits from an independent review?
Stakeholders across governance, compliance and growth
Board and senior management
Independent visibility of control design and operating effectiveness.
MLRO / Compliance Officer
Evidence-led support for oversight, testing and remediation planning.
Fintech founders & payment businesses
Structured assessment ahead of growth, partnerships or regulatory scrutiny.
Financial institutions & investors
Clear documentation to inform risk and investment decisions.
Commercial partners & aggregators
Independent validation that can support counterparty due diligence.
Banking relationships & regulatory preparation
Documented testing that supports management and third-party processes.
Professional credentials
Led by Waqas Mumtaz, ACA (ICAEW), ACA (ICAP)
Extensive experience across banking, internal audit, risk, AML/CFT, financial controls and regulatory compliance.
Does your organisation need an independent AML/CFT review?
Tell us about your business, jurisdiction and review requirements.
Request an AML ReviewDisclaimer: The scope of each engagement is determined by applicable law, regulatory requirements, professional standards and the agreed engagement terms. An AML report is not automatically accepted by every regulator, bank, fintech, aggregator or multinational organisation. Reports are prepared for the intended users and purposes set out in the engagement terms.