Would your client files stand up to the FCA? Find out before they ask.
An independent, investigator-led onboarding assurance review of the due diligence behind your clients, especially the high-risk ones, with clear findings and a practical plan to put things right.
Sound familiar?
- You have policies, but you are not sure they are followed. Procedures look sound on paper, but nobody has independently tested what actually happened at onboarding.
- High-risk clients were waved through. Complex ownership structures, offshore entities, PEPs and screening hits cleared with no recorded rationale.
- Source of funds and source of wealth are thin. A declaration on file, but no evidence and no challenge.
- Database checks gave a clean result. Your screening tool found nothing, but risk often sits in context, hidden connections, nominee arrangements and adverse media a database never surfaces.
- Your team is too stretched, or too close. A remediation backlog, a periodic review programme that slipped, and no one with the time or independence to look with fresh eyes.
- The regulator is already asking questions. A supervisory visit, a Dear CEO letter, a restriction on your business, or a s166 review on the horizon, and you need credible evidence quickly.
- Your AML supervisor is about to change. Law firms, accountants and trust and company service providers are moving to FCA supervision, with tougher scrutiny and higher penalties.
How we help
We test your due diligence the way an investigator would, and the way a regulator increasingly will. We do not just check that boxes are ticked: we check whether the conclusions on file were justified, and we verify the highest-risk clients independently.
You find out where the gaps are, how serious they are, and exactly what to fix first, before a regulator or a problem client finds them for you.
How it works
- Scoping call. We agree the scope, your risk profile and a risk-based sample of client files, weighted towards high-risk relationships.
- File testing. Each file is tested against the Money Laundering Regulations 2017, the relevant sector guidance and your own policies, identification and verification, beneficial ownership, risk rating, screening, source of funds and wealth, and ongoing monitoring.
- Independent verification. For high-risk clients we go beyond the file, using open-source investigation and our EDD-Pro platform to test whether the picture you were given holds up.
- Findings. Every issue is graded by severity, with the root cause identified, whether that is people, process, policy or systems.
- Report and remediation plan. A clear written report with a prioritised plan your board, your MLRO and, where needed, your regulator can act on.
- Follow-up (optional). Re-testing after remediation, and practical training for your onboarding and compliance teams.
What you receive
- A written report with an executive summary for senior management and the board
- File-by-file findings, graded by severity
- Root-cause analysis and a prioritised remediation plan
- A briefing for your MLRO and senior management
- Optional: re-testing, policy and procedure review, and CPD-accredited training
Who it is for
- Payment, e-money and other FCA-regulated firms under supervisory pressure or remediating past onboarding
- Law firms, accountancy practices and trust and company service providers preparing for FCA supervision
- Firms acquiring a client book, or onboarding into new high-risk markets
- Specialist consultancies and law firms needing an experienced investigator to support a review
The FCA is taking over AML supervision of professional services
The FCA will become the single anti-money laundering supervisor for legal, accountancy and trust and company services, replacing 22 professional body supervisors and overseeing around 60,000 firms. The first firms are expected to come under FCA supervision before the end of 2028.
The FCA supervises differently. It is data-led, it uses skilled person reviews and business restrictions, and its penalties are on another scale: the largest recent SRA AML fine was broadly equal to the smallest FCA AML fine in 2023/24.
The rules are not changing; the scrutiny is. The firms that move across with confidence will be the ones that have already tested their client files. An Onboarding Assurance Review gives you that evidence now, while there is still time to fix what it finds.
Why Intelect
- Investigator-led, not database-led. Led by Colin Tansley, a former Detective Superintendent with 45 years in investigations and over 15 years specialising in due diligence.
- We know what good looks like, because we teach it. Intelect has trained thousands of compliance, legal and financial professionals in due diligence, in the UK and internationally.
- High-risk and offshore experience. Due diligence for clients across the Crown Dependencies, Gibraltar, Malta, Europe and beyond, including Citizenship by Investment programmes.
- Technology that supports judgement. EDD-Pro, our enhanced due diligence platform, speeds up screening and gives a clear audit trail, while the conclusions stay with an experienced investigator.
- Recognised. Asset Tracing Company of the Year, FM Global Awards 2022.
- Independent and confidential. We work directly with your firm, or alongside your solicitors and consultants.
Know what is in your client files before the regulator does.
Book a confidential, no-obligation call to discuss an Onboarding Assurance Review.