Case Study

Fincrime Audit

June 28, 2019


A London based money transmission firm.


The objective was to conduct a full-scope compliance audit of the firm’s business processes, documented policies, personnel and controls, in order to compare its existing compliance procedures against the regulatory obligations to which it is subject. This included all obligations relating to applicable anti-money laundering and counter terrorist financing regulations and legislation, including domestic and international sanctions regimes, as well as all regulatory compliance obligations applicable to a global money transmission firm.

Approach to engaging with the client

The initial client engagement began with a kickoff call between the client compliance team and the fscom audit team. The kickoff call outlines the documentation requested for pre-audit review, laid out the audit agenda and introduces both teams and provides an opportunity for any initial questions.

fscom undertook an initial off-site document review, before conducting a period of on-site testing to test all components of the firm’s AML/CTF framework; this included walkthroughs of all procedures in practice, testing of CDD files held on customers and interviews with key personnel (in order to gauge the wider culture of compliance in place at the firm).

On completion of the testing component, initial results were presented to representatives of the money transmission firm, in order to confirm findings and allow for management response.


The outcome of the project was the full audit report which was presented to the investment firm, in order to demonstrate that all expected standards have been met; this contained all findings and issues as identified, the relevant legislation and industry guidance that each finding breaches, an objective risk rating and recommendations how each issue may be remediated.

With fscom’s assistance, the investing firm completed its due diligence process and participated as fully in the funding round.