What is a TCSP AML independent review?
It is an independent review of a TCSP licensee’s AML/CFT policies, procedures, records and control implementation. It usually covers risk assessment, CDD, screening, monitoring, STR, record keeping, staff training and related controls.
Is AML independent review the same as statutory audit?
No. A statutory audit focuses on financial statements. An AML independent review focuses on AML/CFT systems, controls, records and implementation.
Do Hong Kong TCSP licensees need AML independent review?
TCSP licensees are expected to maintain effective AML/CFT systems and controls. An independent review helps the licensee assess whether those systems are adequate and operating effectively.
What is included in the AML/CFT Independent Review Report?
The report covers the agreed scope, review observations, findings and recommendations. Add-ons such as policy manuals, forms or training are separate service scope extensions.
Does the report include sample file review?
Where relevant, the review may include risk-based review of selected client files and compliance records. We describe this as risk-based client file review rather than a separate product.
How long does the review take?
A standard review can often be completed within 2 – 4 weeks, subject to document readiness, responsiveness and agreed scope.
How much does it cost?
Fees depend on active client count, business model, risk profile, document readiness, urgency and whether add-ons are requested. We can provide an indicative fee after a short intake.
Can the review be done remotely?
Much of the review can usually be handled through documents and online communication, subject to scope and document availability.
Can you update our AML/CFT Policy Manual?
Yes. AML/CFT Policy Manual support can be provided as an add-on for review or implementation clients.
Can you provide CDD, UBO, PEP and EDD forms?
Yes. These are combined in the Customer Onboarding & EDD Forms Pack, which can be provided as an add-on where needed.
Do you provide name screening or outsourced screening?
We review whether the client has an appropriate screening process and records as part of the AML/CFT review. We do not currently provide outsourced ongoing name screening unless separately agreed.
How do we get an indicative quote?
Contact us by WhatsApp or intake form and provide a few details including licence status, active client number, TCSP services, risk profile and target timeline.