Client stories

What remained after the findings memo

The licensing readiness audit caught three policy gaps our counsel had not flagged — mainly around remittance agent oversight. Fieldwork took longer than we hoped because our evidence index was messy, but the final memo was clear enough for the board to vote on remediation the same week.
Mei-Ling Chen · Compliance Officer, electronic payment applicant · Licensing Readiness Audit

We asked for an AML control assessment after a supervisory follow-up letter. Sampling stayed out of the onboarding queue, which mattered during Lunar New Year volume. One medium finding on sanctions re-screening still sits with us; the rest were closed with housekeeping.
David Hsu · Head of Operations, remittance firm · AML Control Assessment

Our audit committee used the board assurance briefing to decide whether to expand a processor relationship. The session was blunt about residual vendor risk. I would have liked more time on capital implications, but the follow-up note gave the company secretary what she needed for the minutes.
Helena Wu · Independent Director · Board Assurance Briefing

The vendor control review on our call-center partner produced a memo we attached to the outsourcing pack without rewriting. Access logs from the vendor arrived late, which delayed the draft by a week — something to plan for if your contracts lack firm evidence SLAs.
Kenji Park · Risk Lead, prepaid card issuer · Outsourced Vendor Control Review

Extended case

Payment applicant — licensing readiness before a Q2 filing

A single-entity electronic payment applicant approached Stonegate eight weeks before counsel planned to lodge materials. The evidence index listed policies by internal project names rather than licensing criteria, which slowed the first two fieldwork days.

Sampling of onboarding files showed incomplete elevated-risk approvals for agent-introduced merchants. The draft findings memo ranked three high items: agent oversight policy, sanctions re-screening frequency, and board minutes that lacked capital discussion extracts.

Management closed two items before final report; agent oversight remained open with a dated remediation plan attached for the board. Counsel used the final assurance letter as an annex to internal filing readiness notes. The engagement did not include legal representation or STR filing.

Extended case

Remittance operator — AML assessment after a follow-up letter

Following a supervisory letter on transaction monitoring, the operator commissioned an AML control assessment covering a six-month population. Samples were drawn by corridor risk so peak Lunar New Year onboarding continued without auditors borrowing physical deskside files.

One medium finding on delayed sanctions re-screening for dormant accounts that reactivated remained open at close-out. Lower findings were housekeeping on folder naming. The management letter’s worksheets were reused by internal audit for a subsequent quarter sample.

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