Independent AML Testing
Independent reviews of anti-money laundering programmes for money transmitters, money services businesses and payment fintechs, built for examiners and partner banks to rely on.
An independent AML review tests whether a money services business's anti-money laundering programme works, as 31 C.F.R. 1022.210 requires. We test every element (risk assessment, controls, reporting, record keeping, training and the compliance officer's work) on samples of real transactions, and deliver a rated findings report with agreed corrective actions.
Speak to a compliance expertSpeak to a compliance expert
Tell us the business, the states you hold licences in and where your programme stands. Every enquiry is answered the same business day, with a written proposal setting out the scope, the team and the timing.
Your enquiry
What we do
Every money services business must have its anti-money laundering programme independently reviewed, with scope and frequency matched to its risk. FinCEN's guidance allows an employee to do it, but never the designated compliance person or anyone who reports to them. Examiners and partner banks ask for the latest review, and the firm's response to it, before almost anything else.
Our reviews test operation, not only documents. We take samples of customer files, transactions, alerts, suspicious activity and currency transaction reports, screening hits, agent files and training records, and test them against your written programme and the rules. Each finding is rated, traced to its cause and agreed with management, with an owner and a date. We return to test that the fixes work. See [what examiners check across the year](/insights/money-transmitter-compliance-requirements-2026).
We do not test a programme we help to run. If we provide [BSA programme support](/services/outsourced-bsa-officer) to your firm, we will tell you to appoint a different reviewer.
Scoping
We read the risk assessment and agree products, states, agents, period covered and sample sizes, set out in a scoping memo.
Fieldwork
Document review, interviews with the compliance officer and staff, and testing of transactions, alerts and reports.
Findings
Each finding rated by severity with its root cause, discussed with management before the report is final.
Report and follow-up
A final report for the board, examiners and partner banks, then follow-up testing of corrective actions.
What's Included
Scoping memo
The areas, period, sample sizes and timetable, agreed before fieldwork starts.
Programme review
The written programme and risk assessment tested against the rules and against how the business really operates.
Transaction and alert testing
Samples of customers, transfers and alerts traced from start to finish.
Reporting test
Suspicious activity and currency transaction reports checked for quality, aggregation and timeliness.
Rated findings report
Findings by severity, with root causes, management responses, owners and dates.
Follow-up testing
Corrective actions re-tested and closed, with evidence for the next examination.
What the review covers
Scope follows FinCEN's guidance on independent reviews (FIN-2006-G012) and is set by your risk assessment.
| Area | What we test | Evidence examined |
|---|---|---|
| Risk assessment | It reflects current products, customers, channels and geography | Risk assessment, product list, volumes by corridor |
| Customer identification and due diligence | Records meet the policy and the rules | Sample of customer files |
| Transaction monitoring | Rules fit the risks and alerts are reviewed on time | Rule list, alert sample, case files |
| Suspicious activity reports | Decisions are reasoned and reports filed within 30 days | Report files and no-file decisions |
| Currency transaction reports | Aggregation is correct and reports filed within 15 days | Report sample and cash records |
| Funds transfers | Required details collected and passed on from USD 3,000 | Transfer sample |
| Sanctions screening | Lists are current and hits resolved and recorded | Screening set-up and hit sample |
| Agents | Due diligence, training and monitoring of agents | Agent files and agent transaction monitoring |
| Training | Delivered, current and suited to each role | Training records and materials |
| Compliance officer | Authority, resources and actions taken | Reports, minutes and escalation records |
| Previous findings | Corrective actions completed and effective | Last review and action tracker |
Who this service is for
Firm types
- - State-licensed money transmitters
- - Payment fintechs operating as MSBs
- - Crypto and virtual currency businesses
- - Cheque cashers, currency dealers and prepaid access providers
Situations & Triggers
- - Yearly review due
- - State or IRS examination announced
- - Partner bank due diligence request
- - New product, corridor or acquisition, or an enforcement order requiring reviews
Why firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Related insights
Money Transmitter Compliance Requirements in 2026: The Full Yearly Cycle
Every federal and state compliance obligation for a licensed US money transmitter in one place: the BSA programme, reports, FinCEN registration, net worth, bonds, call reports, renewals and exams.
Money Transmitter Compliance Calendar: November 2026 to December 2027
Every recurring federal and state compliance date for US money transmitters from November 2026 to December 2027: renewals, call reports, Form 107, audited accounts and event-driven deadlines.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a compliance expertFrequently asked questions
Yes. 31 C.F.R. 1022.210(d)(4) requires every money services business to provide for independent review of its anti-money laundering programme, with scope and frequency matched to the risk of its services.
Federal rules set no fixed interval. FinCEN's guidance says frequency should follow the risk assessment, and a review may need to come sooner after problems are found. Most state regulators and partner banks expect one every year, and enforcement orders commonly require it yearly.
An employee or an outside firm, but not the designated compliance person or anyone who reports to them. FinCEN's guidance says a money services business does not necessarily need an outside auditor or consultant.
Every element of the programme: policies, procedures and internal controls, the risk assessment, reporting and record keeping, sanctions screening, agent oversight, training and the actions of the compliance officer, tested on real samples.
It depends on the number of products, states, agents and transactions in scope. We set the timetable in the scoping memo before fieldwork starts, and plan it so that findings can be closed before the NMLS renewal window.
They ask for the latest review and the firm's response to it. A review backed by sample testing, rated findings and documented work papers carries more weight than a review of documents alone.
Yes. For virtual currency businesses we also test blockchain analytics alerts, wallet screening, travel rule data and how the risk assessment treats each asset and network.
Management records a response, an owner and a date for each finding. We return to test the corrective actions and confirm in writing when each is closed.