AML and KYC reviews
A remediated customer book and an AML programme you can evidence to your regulator, your auditors and your banking partners.
Look-back reviews, KYC remediation, transaction-monitoring and sanctions-screening reviews for regulated entities and their partners.
Anti-money laundering obligations are tested in the detail: whether customer files are complete, whether risk ratings make sense, whether monitoring scenarios catch what they should and whether suspicious transactions are reported on time. Gaps usually surface in an inspection, an audit or a correspondent bank's review.
We assess the programme against the Prevention of Money-laundering Act, its rules and your regulator's KYC directions, then test it in practice. Look-back reviews re-examine customers and transactions over a defined period. KYC remediation brings files up to standard, with enhanced due diligence on higher-risk customers, beneficial owners and politically exposed persons.
We also review monitoring scenarios, thresholds and alert handling, sanctions screening and the decisions behind suspicious transaction reports. Where a review finds suspicious activity, we document it so that the reporting entity can decide on reporting to FIU-IND.
A regulator, auditor or correspondent bank has questioned your AML programme, or your customer files need remediation.
Signs we see most often
- 01A regulator's inspection or an auditor has raised AML or KYC observations.
- 02Customer files are incomplete or KYC updates are overdue.
- 03Monitoring generates too many alerts, or too few.
- 04A correspondent bank or partner has questioned your controls.
- 05You are launching a business, product or market with new AML risk.
- 06Trade-based or cross-border flows need closer review.
Scoped in writing, run by one accountable team.
Every engagement starts with agreed questions, a reporting line and a confidentiality protocol. The steps below are how this service usually runs; we adapt them to your matter.
- 01AssessAssess policies, the risk assessment and controls against the law and your regulator's directions.
- 02SampleDefine the look-back population, period and sampling approach.
- 03ReviewReview customer files, transactions and alerts.
- 04RemediateRemediate KYC files and carry out enhanced due diligence where needed.
- 05TuneReview monitoring scenarios, thresholds and screening.
- 06ReportReport findings and support the responses to the board and the regulator.
A remediated customer book and an AML programme you can evidence to the regulator.
- A gap assessment against PMLA and the applicable KYC directions
- Look-back review findings, with cases set out for the reporting decision
- Remediated customer files
- Recommendations on monitoring scenarios, thresholds and screening
- A remediation plan with owners and dates
The law and frameworks this work is aligned to
- Prevention of Money-laundering Act, 2002 and the PML (Maintenance of Records) Rules, 2005
- RBI Know Your Customer Directions, for regulated entities
- SEBI and IRDAI AML and CFT guidelines for the entities they regulate
- FATF Recommendations
- FIU-IND reporting formats and guidance
References show the standard the work is built to. They do not imply accreditation or endorsement by the bodies that publish them.
This is a summary of the service. For a deeper understanding of how it would work for your organisation, please reach out to us.
Talk to a BDI partnerWhere this service meets BDI's technology.
The platforms below record, monitor or act on the work this service produces.
Questions clients ask before we start.
Do you file STRs for us?
No. The reporting entity and its principal officer decide on and file reports with FIU-IND. We document the facts so that the decision can be made and evidenced.
Which entities do you work with?
Banks, NBFCs, payment and fintech companies, insurers and securities market intermediaries, and businesses that need to understand the AML exposure of their partners.
How long does a look-back take?
That depends on the population, the period and the state of the files. We agree scope and sampling at the start so the timeline is clear.