Audit KYC compliance
Regular KYC audits — critical для licensed operator: internal и external.
Internal audits
Quarterly: sampling verified accounts. Documentation completeness. Process adherence. Timing compliance. Staff training records. Vendor SLA adherence. Findings tracked. Remediation plans. Board reporting.
External audits
Annual regulatory audits обычно. Regulator inspections: unannounced. Independent auditors: PwC, KPMG, Deloitte engagements. Certification bodies: ISO 27001, PCI DSS. AML-specific audits: dedicated firms.
Common findings
Documentation gaps. Delayed re-verification. Missing SoF for high-value. PEP screening lapses. Address verification weakness. Automated decision unexplained. Manual override rationale missing. Training records incomplete. Vendor management issues.
Remediation
Immediate: fixes critical findings. 30/60/90-day plans. Board oversight. Root cause analysis. Systematic fixes vs symptoms. Culture changes needed. Repeat findings — serious. Regulator communication proactive. Continuous improvement mindset.