Maintain a defensible control framework aligned to your regulatory obligations.
| Control | Category | Status | Priority | Owner | Last Review | Evidence |
|---|---|---|---|---|---|---|
Expected Activity Profiling at Onboarding At sign-up, ask and record what normal looks like for this customer (how much, how often, to where) so monitoring can later spot when they behave nothing like that. | Customer Due Diligence | Not Started | Medium | Unassigned | Not set | 5 |
Customer Risk Assessment & Rating Score each new and existing customer for money-laundering risk from clear factors (who they are, what they do, where they are) so the firm spends most effort on the riskiest ones. | Customer Due Diligence | Not Started | High | Unassigned | Not set | 7 |
High-Risk Corridor & Geography Monitoring Watches payments to and from higher-risk countries and routes, and flags activity that does not fit the customer or looks designed to disguise where money is really going. | Transaction Monitoring | Not Started | High | Unassigned | Not set | 6 |
Ongoing CDD & Periodic Review Every customer's identity and risk information is refreshed on a fixed schedule so the firm never relies on stale onboarding data. | Ongoing Monitoring | Not Started | Medium | Unassigned | Not set | 5 |
Trigger-Based (Event-Driven) Review When something material changes about a customer, the firm reviews them straight away instead of waiting for the next scheduled review. | Ongoing Monitoring | Not Started | Medium | Unassigned | Not set | 5 |
Dynamic Customer Re-Rating The customer's risk score is recalculated automatically from their real behaviour, so a customer who starts acting riskier is re-rated without waiting for a manual review. | Ongoing Monitoring | Not Started | High | Unassigned | Not set | 5 |
Agent & Distributor Oversight The firm vets and keeps watch over the agents and distributors who sell or move money on its behalf, so a rogue or nested agent cannot smuggle dirty money through its rails. | Ongoing Monitoring | Not Started | High | Unassigned | Not set | 5 |
SAR / STR Process & Timeliness A clear, fast route for staff to raise a suspicion, for the MLRO to decide, and for a report to reach the authorities on time without tipping off the customer. | Governance & Reporting | Not Started | High | Unassigned | Not set | 7 |
Alert & Case Backlog Management Stop financial crime alerts and cases piling up unworked by tracking how old they are, fixing the cause, and stepping in fast when the queue grows. | Governance & Reporting | Not Started | High | Unassigned | Not set | 6 |
Showing 1 to 9 of 9 controls
This tool produces a control specification for design and discussion. It is not legal advice; validate thresholds, ownership and status against your own risk assessment and the cited sources before implementing. Your register is kept in this browser (not on a server); we only store the contact details you provide when you request an export.