Every compliance and risk professional knows the drill: when the auditors arrive, the pressure is on. For financial-crime teams in fintechs and payments firms in particular, the stakes go far beyond a tick-box exercise. This audit isn’t about process for process’s sake; it’s a chance to evidence that your anti-financial crime framework is doing what it’s designed to do: protect your customers and your firm, while giving regulators confidence you’re on top of it.
If your last audit felt like a fire-drill, or you’ve never had a formal review of your AFC (anti-financial crime) controls, then this article is for you. Here are 11 practical, tried-and-tested tips to help you move from “audit-alert” to genuinely “audit-ready”, so you’ll face the next assessment with more calm, more rigour and less stress.
1. Auditor profiles matter
Do you actually know who is conducting the audit? Many regulators talk about fit and proper tests for those in regulated roles, but it’s reasonable to expect that your auditor is qualified for the job as well. An auditor with demonstrable FinCrime experience in your industry will spot genuine control gaps rather than generic compliance issues.
2. Define scope
It may sound obvious, but make sure you have a defined scope with your auditors so you understand what FinCrime topics they are covering and how. This should also align to your local regulators’ and banking partners’ expectations. Clarity upfront prevents scope creep and misaligned findings later.
3. Be mindful of time
Make sure you have a full understanding of how long your FinCrime auditors are spending through the process. Whilst a short, light touch audit may sound good in principle, the likelihood is they are going to miss something, and that can lead to bigger issues later.
4. Be prepared
Much of the work we do in FinCrime is often reactive, but as you’ve organised the audit, you can be prepared for it. For instance:
Does your senior manager know they are going to be interviewed?
Are the team aware they will be involved in thematic sessions/testing?
Are you able to retrieve tasks completed by your team which auditors may want to review?
The more planning you do, the smoother the process, and the more value you’ll get from the feedback.
Check out our Audit Checklist to dentify any potential AFC framework gaps before your next review.
5. Be aware of regulatory changes
Regulatory audit changes are a constant battle for everyone, but it’s important to stay on top of them. Knowing what has changed since your last audit and whether you have implemented it will certainly be a question for most auditors.
6. Honest self declarations
Within any kick-off session or self declaration session, try to be honest about the current situation. If you have a gap in your AFC framework, the likelihood is your auditors are going to find it. It is better to be honest with obvious gaps you are aware of and be able to demonstrate you are taking proactive measures to resolve them.
7. Collaborative, not combative
This point refers to both parties. There is no need for either side of the table to create a combative environment. Ultimately, a good auditor wants to provide you with useful information on where you need enhancements. This can be done in a considerate way without intimidating the life out of your analysts.
8. Challenge findings
It is perfectly acceptable to challenge your findings or the rating of the findings. You should have a closing session with your auditors and make sure you come prepared with evidence why you disagree - just telling them you don’t agree is not going to be sufficient justification for closing a recommendation.
9. Practical recommendations
In our view at FINTRAIL, a good audit report will not only highlight areas of deficiencies, but also elaborate on expectations of how to resolve the issue. Just telling you that you do not meet line 1.3.11 of the AML Regulations or line 2.4.7 of the Bank Secrecy Act isn’t actually that helpful! Don’t be shy about asking for practical recommendations to resolve issues.
10. Track your findings
Once your audit is complete, make sure you track your findings, allocate them to someone specific, and prioritise them against the ratings provided. Auditors know you won’t be able to do everything at once - but come the following year, you will need to be able to present sufficient progress against closing last year’s findings.
11. Opportunities for budget and project approvals
Audits can be a catalyst for change. Use the findings to make a clear, evidence-based case for additional budget, new tooling, or headcount; it’s one of the few times you’ll have data directly supporting your business case.
Selecting the Right Audit Partner
By following these steps, you’ll set your firm up for a smoother, more valuable audit experience. But ultimately, the quality of your audit also depends on who you partner with.
At FINTRAIL, our audit professionals bring hands-on experience from senior and operational roles across leading global banks and fintechs. We’ve seen first-hand what good looks like in practice, and we apply that insight to every review.
Our audits are aligned with relevant regulatory requirements and industry standards, covering firms across the UK and multiple international jurisdictions. We’re also approved by several major banking partners — a reflection of the trust placed in our approach and expertise.
Beyond the audit itself, we help firms turn findings into action. Whether that means remediating recommendations from another provider, or benchmarking your controls against peers, our goal is to help you strengthen your anti-financial crime framework in a practical, sustainable way.
Our clients value us for our deep industry expertise and exceptional client service.
To learn more about our financial crime audit and assurance services, speak to our team.