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A regulator or internal audit report rarely hurts because it’s surprising. It hurts because it exposes gaps you already suspected, then forces you to prove – quickly – that you can control your risk. An effective remediation response is not a promise to “do better”. It is a disciplined programme that fixes root causes, tightens decision-making, and produces evidence that will stand up to follow-up testing.
This is where many firms lose time. They treat remediation as a documentation exercise and then discover, at re-test, that the underlying control still fails in practice. A defensible aml audit remediation plan is different: it is designed for execution, governance and proof.
What an AML audit remediation plan really needs to achieve
An audit finding is not the problem. The problem is the operational reality behind it: inconsistent onboarding decisions, incomplete customer files, unclear escalation paths, weak monitoring logic, poor quality MI, or controls that exist on paper but not in the workflow.
A remediation plan should therefore do three things at once.
First, it must reduce risk. That means the control environment after remediation should materially lower the likelihood of money laundering exposure, not just look tidier.
Second, it must be testable. If you cannot produce evidence that a control operated effectively over a period, you are vulnerable to repeat findings.
Third, it must be owned. Remediation without accountable owners, timelines, and clear acceptance criteria becomes an endless “open action” list that management cannot credibly sign off.
Start with the finding, then reframe it as a control failure
Audit reports often describe symptoms: “CDD files missing source of funds”, “risk assessments inconsistent”, “transaction monitoring alerts not documented”. Remediation begins by translating each finding into a control statement that can be designed, operated, and tested.
For example, “missing source of funds” is not a gap in a file. It is a failure in the customer due diligence process design, training, quality assurance, or system gating. If your onboarding workflow allows a relationship to be approved without mandatory evidence, the control is structurally weak. If the workflow blocks approval but staff bypass it through workarounds, the control is culturally weak.
That distinction matters because it determines whether you should fix policy wording, system configuration, staffing, training, or oversight. Most repeat findings happen when firms remediate the wording.
Do root cause analysis that is specific enough to act on
Root cause analysis should be uncomfortable, not abstract. “Capacity constraints” is not a root cause. “No defined SLA for EDD reviews, resulting in approvals without MLRO sign-off” is.
A practical approach is to ask two questions for each finding:
Who made the decision, using what information, under what time pressure?
Where was the control supposed to intervene, and why did it not?
You will usually land on one or more of these root causes: unclear risk appetite, weak governance over risk scoring, inadequate systems support, ineffective QA, fragmented ownership between Compliance and Operations, or insufficient competence for the complexity of the client base.
It depends on your business model. A payments firm onboarding high volumes at speed will face different failure modes from a corporate service provider handling fewer, higher-risk relationships. The plan should reflect that reality, not force a generic fix.
Prioritise actions using risk, not convenience
Remediation sequencing should follow exposure. High-risk client segments, high-risk geographies, and products with greater abuse potential should be addressed first. A common error is prioritising what is easiest to close quickly, which creates a neat tracker but leaves core risk untouched.
When setting priorities, consider whether the finding relates to:
customer onboarding and acceptance decisions (often the highest immediate exposure)
ongoing monitoring and detection capability (risk accumulates over time)
suspicious reporting governance (late or inconsistent reporting can be a significant regulatory concern)
sanctions screening and PEP handling (binary failures can be severe)
If multiple findings are linked to the same broken process, treat them as a remediation theme rather than separate tasks. That is how you reduce total effort and avoid contradictory fixes.
Build the plan around five pillars
A remediation plan that holds up is usually built across five pillars: governance, risk assessment, customer due diligence, monitoring and reporting, and assurance. You may not need major work in all five, but you do need to show you considered them.
1) Governance and accountability
Auditors and regulators look for management control: clear responsibility, oversight, and timely escalation. In practical terms, ensure your plan includes named owners for every action, a steering cadence (weekly for acute issues, monthly for longer programmes), and decision logs for key design choices.
Define acceptance criteria in plain language: what “fixed” looks like, what evidence will prove it, and who signs it off. Without this, actions get closed because the due date arrived, not because the control works.
2) Risk assessments that drive decisions
Many remediation programmes fail because the Business Risk Assessment (BRA) and customer risk methodology are treated as static documents. Yet they should drive your controls, thresholds, and resourcing.
If your audit highlighted inconsistent risk scoring, address the method and the operating model. Are risk factors clearly defined? Are weightings justified? Are overrides controlled and documented? Are high-risk triggers mapped to mandatory EDD and approval levels?
A strong remediation outcome is not “updated risk assessment”. It is a risk assessment that demonstrably changes onboarding decisions, review cycles, and monitoring intensity.
3) CDD and EDD process fixes that reduce rework
CDD remediation should focus on the workflow and quality gates. Policy changes help, but they rarely fix missing evidence at scale.
If you have file gaps, decide whether you need a targeted remediation of high-risk relationships, a broader file uplift, or both. A targeted approach is often more defensible if risk is clearly prioritised and documented. A full population uplift can be appropriate where the methodology itself was flawed, but it is resource-heavy and can create operational disruption.
Make sure the plan addresses practical questions: what documents are acceptable for source of wealth vs source of funds, what verification steps are required, what constitutes an adverse media hit, and how you record rationale for acceptance. Consistency is as important as completeness.
4) Monitoring, screening, and suspicious reporting
If transaction monitoring and sanctions screening are in scope, remediation should cover both system settings and human decisioning.
For monitoring, you need to be able to explain why your scenarios and thresholds are appropriate for your products and customers, and how you tune them. For many firms, the gap is not lack of alerts but poor alert handling: weak narratives, missing evidence, inconsistent outcomes, and no second-line oversight.
For suspicious reporting governance, remediate timeliness, escalation and documentation. A regulator will not accept “we discussed it verbally”. Ensure case files show the trigger, analysis performed, decision made, and MLRO rationale.
5) Assurance, QA and proof of effectiveness
Remediation is not complete when you change a process. It is complete when you can prove it operated effectively over time.
Build a QA framework that tests the remediated controls. This can include file reviews, monitoring case quality checks, and targeted re-testing aligned to the original audit scope. Define sample sizes and frequency based on risk, and record outcomes with clear defect taxonomy so you can show trending and learning.
Make evidence a deliverable, not an afterthought
Your plan should specify what evidence each action will produce. Examples include system screenshots of mandatory fields, policy versions with approval minutes, training completion records, QA results with defect rates, and MI showing changes in risk distribution or alert outcomes.
Evidence has a trade-off: it takes time to create and maintain. But it also reduces future disruption. Firms that treat evidence as part of the operating model spend less time scrambling for “proof” during the next audit.
Avoid the three remediation traps auditors see repeatedly
The first trap is closing actions on paper. A revised procedure does not mean staff follow it, particularly in high-volume onboarding environments.
The second trap is over-correcting. If you respond to findings by adding layers of approvals and documents without adjusting workflow and resourcing, you may slow onboarding, frustrate the business, and still not improve quality.
The third trap is ignoring data. If your customer risk ratings, review dates, and CDD status fields are inconsistent, every downstream control becomes unreliable. Data quality remediation is not glamorous, but it is often the difference between a stable programme and constant manual workarounds.
What good looks like at re-test
At re-test, you want to demonstrate three outcomes: the control design is appropriate, the control operated consistently, and exceptions were identified and corrected.
That means your remediation tracker should link each action to the relevant policy or control, show the implementation date, and show a period of operation with QA results. If you had to accept interim risk, document it with compensating controls and management approval. Regulators understand sequencing, but they do not accept unmanaged exposure.
When to bring in external support
Some remediation can be handled in-house, especially where the issues are narrow and your team has capacity. External support becomes valuable when findings are thematic, when you need an independent view to rebuild credibility, or when you must remediate quickly without breaking day-to-day operations.
A partner can help translate findings into implementable controls, design defensible testing, and produce reporting that management and regulators can rely on. Where that support is hands-on and tailored, it often reduces the total time-to-close because you avoid rework. Complipal provides this kind of advisory-led remediation support, aligning actions to a risk-based control framework and focusing on evidence that stands up to scrutiny: https://complipal.com.
A final thought to keep the programme grounded: every remediation action should make a future decision easier – easier to onboard consistently, easier to spot risk early, and easier to prove you did the right thing when someone asks.
AML audit remediation plan that holds up
A regulator or internal audit report rarely hurts because it’s surprising. It hurts because it exposes gaps you already suspected, then forces you to prove – quickly – that you can control your risk. An effective remediation response is not a promise to “do better”. It is a disciplined programme that fixes root causes, tightens decision-making, and produces evidence that will stand up to follow-up testing.
This is where many firms lose time. They treat remediation as a documentation exercise and then discover, at re-test, that the underlying control still fails in practice. A defensible aml audit remediation plan is different: it is designed for execution, governance and proof.
What an AML audit remediation plan really needs to achieve
An audit finding is not the problem. The problem is the operational reality behind it: inconsistent onboarding decisions, incomplete customer files, unclear escalation paths, weak monitoring logic, poor quality MI, or controls that exist on paper but not in the workflow.
A remediation plan should therefore do three things at once.
First, it must reduce risk. That means the control environment after remediation should materially lower the likelihood of money laundering exposure, not just look tidier.
Second, it must be testable. If you cannot produce evidence that a control operated effectively over a period, you are vulnerable to repeat findings.
Third, it must be owned. Remediation without accountable owners, timelines, and clear acceptance criteria becomes an endless “open action” list that management cannot credibly sign off.
Start with the finding, then reframe it as a control failure
Audit reports often describe symptoms: “CDD files missing source of funds”, “risk assessments inconsistent”, “transaction monitoring alerts not documented”. Remediation begins by translating each finding into a control statement that can be designed, operated, and tested.
For example, “missing source of funds” is not a gap in a file. It is a failure in the customer due diligence process design, training, quality assurance, or system gating. If your onboarding workflow allows a relationship to be approved without mandatory evidence, the control is structurally weak. If the workflow blocks approval but staff bypass it through workarounds, the control is culturally weak.
That distinction matters because it determines whether you should fix policy wording, system configuration, staffing, training, or oversight. Most repeat findings happen when firms remediate the wording.
Do root cause analysis that is specific enough to act on
Root cause analysis should be uncomfortable, not abstract. “Capacity constraints” is not a root cause. “No defined SLA for EDD reviews, resulting in approvals without MLRO sign-off” is.
A practical approach is to ask two questions for each finding:
Who made the decision, using what information, under what time pressure?
Where was the control supposed to intervene, and why did it not?
You will usually land on one or more of these root causes: unclear risk appetite, weak governance over risk scoring, inadequate systems support, ineffective QA, fragmented ownership between Compliance and Operations, or insufficient competence for the complexity of the client base.
It depends on your business model. A payments firm onboarding high volumes at speed will face different failure modes from a corporate service provider handling fewer, higher-risk relationships. The plan should reflect that reality, not force a generic fix.
Prioritise actions using risk, not convenience
Remediation sequencing should follow exposure. High-risk client segments, high-risk geographies, and products with greater abuse potential should be addressed first. A common error is prioritising what is easiest to close quickly, which creates a neat tracker but leaves core risk untouched.
When setting priorities, consider whether the finding relates to:
If multiple findings are linked to the same broken process, treat them as a remediation theme rather than separate tasks. That is how you reduce total effort and avoid contradictory fixes.
Build the plan around five pillars
A remediation plan that holds up is usually built across five pillars: governance, risk assessment, customer due diligence, monitoring and reporting, and assurance. You may not need major work in all five, but you do need to show you considered them.
1) Governance and accountability
Auditors and regulators look for management control: clear responsibility, oversight, and timely escalation. In practical terms, ensure your plan includes named owners for every action, a steering cadence (weekly for acute issues, monthly for longer programmes), and decision logs for key design choices.
Define acceptance criteria in plain language: what “fixed” looks like, what evidence will prove it, and who signs it off. Without this, actions get closed because the due date arrived, not because the control works.
2) Risk assessments that drive decisions
Many remediation programmes fail because the Business Risk Assessment (BRA) and customer risk methodology are treated as static documents. Yet they should drive your controls, thresholds, and resourcing.
If your audit highlighted inconsistent risk scoring, address the method and the operating model. Are risk factors clearly defined? Are weightings justified? Are overrides controlled and documented? Are high-risk triggers mapped to mandatory EDD and approval levels?
A strong remediation outcome is not “updated risk assessment”. It is a risk assessment that demonstrably changes onboarding decisions, review cycles, and monitoring intensity.
3) CDD and EDD process fixes that reduce rework
CDD remediation should focus on the workflow and quality gates. Policy changes help, but they rarely fix missing evidence at scale.
If you have file gaps, decide whether you need a targeted remediation of high-risk relationships, a broader file uplift, or both. A targeted approach is often more defensible if risk is clearly prioritised and documented. A full population uplift can be appropriate where the methodology itself was flawed, but it is resource-heavy and can create operational disruption.
Make sure the plan addresses practical questions: what documents are acceptable for source of wealth vs source of funds, what verification steps are required, what constitutes an adverse media hit, and how you record rationale for acceptance. Consistency is as important as completeness.
4) Monitoring, screening, and suspicious reporting
If transaction monitoring and sanctions screening are in scope, remediation should cover both system settings and human decisioning.
For monitoring, you need to be able to explain why your scenarios and thresholds are appropriate for your products and customers, and how you tune them. For many firms, the gap is not lack of alerts but poor alert handling: weak narratives, missing evidence, inconsistent outcomes, and no second-line oversight.
For suspicious reporting governance, remediate timeliness, escalation and documentation. A regulator will not accept “we discussed it verbally”. Ensure case files show the trigger, analysis performed, decision made, and MLRO rationale.
5) Assurance, QA and proof of effectiveness
Remediation is not complete when you change a process. It is complete when you can prove it operated effectively over time.
Build a QA framework that tests the remediated controls. This can include file reviews, monitoring case quality checks, and targeted re-testing aligned to the original audit scope. Define sample sizes and frequency based on risk, and record outcomes with clear defect taxonomy so you can show trending and learning.
Make evidence a deliverable, not an afterthought
Your plan should specify what evidence each action will produce. Examples include system screenshots of mandatory fields, policy versions with approval minutes, training completion records, QA results with defect rates, and MI showing changes in risk distribution or alert outcomes.
Evidence has a trade-off: it takes time to create and maintain. But it also reduces future disruption. Firms that treat evidence as part of the operating model spend less time scrambling for “proof” during the next audit.
Avoid the three remediation traps auditors see repeatedly
The first trap is closing actions on paper. A revised procedure does not mean staff follow it, particularly in high-volume onboarding environments.
The second trap is over-correcting. If you respond to findings by adding layers of approvals and documents without adjusting workflow and resourcing, you may slow onboarding, frustrate the business, and still not improve quality.
The third trap is ignoring data. If your customer risk ratings, review dates, and CDD status fields are inconsistent, every downstream control becomes unreliable. Data quality remediation is not glamorous, but it is often the difference between a stable programme and constant manual workarounds.
What good looks like at re-test
At re-test, you want to demonstrate three outcomes: the control design is appropriate, the control operated consistently, and exceptions were identified and corrected.
That means your remediation tracker should link each action to the relevant policy or control, show the implementation date, and show a period of operation with QA results. If you had to accept interim risk, document it with compensating controls and management approval. Regulators understand sequencing, but they do not accept unmanaged exposure.
When to bring in external support
Some remediation can be handled in-house, especially where the issues are narrow and your team has capacity. External support becomes valuable when findings are thematic, when you need an independent view to rebuild credibility, or when you must remediate quickly without breaking day-to-day operations.
A partner can help translate findings into implementable controls, design defensible testing, and produce reporting that management and regulators can rely on. Where that support is hands-on and tailored, it often reduces the total time-to-close because you avoid rework. Complipal provides this kind of advisory-led remediation support, aligning actions to a risk-based control framework and focusing on evidence that stands up to scrutiny: https://complipal.com.
A final thought to keep the programme grounded: every remediation action should make a future decision easier – easier to onboard consistently, easier to spot risk early, and easier to prove you did the right thing when someone asks.
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