- Fintechs and regulated businesses reviewing a risk-based AML/CFT programme
- Boards, senior management, MLROs, compliance teams and internal reviewers
- Businesses preparing for licensing, audit, remediation or material product change
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AML/CFT & regulatory compliance
AML/CFT Programme Gap Checklist
A board-to-operations review aid for risk assessment, onboarding, monitoring, reporting, training, testing and remediation.
Free working resourceEditable Word document (.docx)KenyaReviewed 31 July 2026
- Confirming that a business is compliant with every applicable obligation
- Replacing sector-specific rules, sanctions advice or an independent assurance review
- Recording customer or transaction information in a file shared with the firm
What is included
A structured starting point you can control.
- 01
Governance, enterprise and product risk assessments
- 02
CDD, beneficial ownership, PEP, sanctions and enhanced-measure controls
- 03
Monitoring, escalation, reporting, record retention and training
- 04
Independent testing, findings, action owners and board reporting
Use offline; do not upload confidential information.
The resource is designed to be downloaded and completed within your own controlled environment. It is a general working aid, not legal advice, a compliance certification, an executable agreement or a prediction of any regulator’s decision.
When the facts need judgment
Request a scope and fee Turn the completed working aid into a defined legal mandate.
Send a short, non-confidential scope request. The firm ordinarily responds within one business day and will confirm conflicts, engagement terms, scope and fees before substantive review.
No duty to update this resource is assumed. Check current official sources and obtain advice on the complete facts before acting. Read the full disclaimer.