If your business was last audited in 2023, your three-year audit cycle is coming due. Your programme has likely been operating in a regulatory environment that has changed meaningfully since then — new guidance, new expectations, and soon a new supervisory structure.
Why your 2023 programme may not pass a 2026 audit
The regulatory landscape has shifted. AML/CFT typologies have evolved, risk assessment methodologies have become more prescriptive, CDD expectations are clearer, and training and documentation standards have risen. A programme that was compliant in 2023 may have significant gaps when audited against 2026 expectations.
5 things to check now
1. Risk assessment currency — Does it reflect current risks, emerging typologies, and business evolution? A risk assessment from 2023 is likely to miss emerging exposures.
2. CDD procedures — Are they documented, followed consistently, and aligned with current guidance? Can you evidence that due diligence was conducted on each customer?
3. Training records — Is your team trained on current expectations? Can you provide records of training completion and comprehension?
4. Transaction monitoring — Are your thresholds and triggers still appropriate? Have they been reviewed in light of business growth or changes in transaction patterns?
5. Suspicious activity reporting — Do staff know when to report and how to document the decision? Can you evidence that suspicious activity has been properly evaluated and reported or declined?
The cost of leaving it too late
Businesses that come to an audit with outdated programmes face two problems: the audit itself may identify significant gaps, and remediation under time pressure is more expensive and disruptive than proactive review. An audit finding requires documented remediation, which takes time and resources.
Strategi’s AML/CFT audits are designed to identify gaps early and help businesses strengthen their compliance position before the formal supervisor audit — not just pass the audit, but build a robust programme for the years ahead.
Contact us to arrange an AML/CFT audit or programme review before your three-year cycle comes due.