If your business was last audited in 2023, your three-year audit cycle is coming due. But this is not the same regulatory environment it was three years ago. The AML/CFT landscape has shifted — new guidance, evolving typologies, updated expectations around risk assessments and transaction monitoring, and now a new supervisory structure from 1 July.
Why 2023 is a critical audit cohort
2023 was a peak audit year across the sector. Many businesses completed their audits under guidance and expectations that have since been updated. The risk is going into a 2026 audit with a 2023 programme.
What has changed since your last audit
Key shifts include: updated DIA guidance on risk assessments, evolving CDD expectations, new typology reports, changes to suspicious activity reporting thresholds, and the Single Supervisor Transition itself.
The cost of waiting
Businesses that wait until their audit is imminent to review their programme face two problems: less time to address gaps, and higher remediation costs when issues are found under pressure. Many businesses that were audited in 2023 are already reviewing their programmes now, well ahead of their next audit date.
If your last audit was in 2023, the smartest move is to review your programme now — while there is still time to address gaps at your own pace. Strategi’s AML/CFT audits are structured to give you a clear picture of where you stand and a practical path to audit readiness.