Independent RMCP and BRA Desktop Compliance Review Service

Is Your RMCP Truly Inspection Ready?

Many accountable institutions have invested significant time and resources in developing Risk Management and Compliance Programmes (RMCPs) and Business Risk Assessments (BRAs). However, as regulatory expectations continue to evolve, a growing number of firms are discovering that having an RMCP is not necessarily the same as having an RMCP that is adequately structured, risk-based, defensible and aligned to current Financial Intelligence Centre (FIC) expectations.

Recent inspection trends indicate increasing regulatory focus on the quality, adequacy and practical application of AML/CFT frameworks. Regulators are no longer simply asking whether an RMCP exists. They are assessing whether the RMCP demonstrates a genuine understanding of the institution’s risks and whether those risks are appropriately addressed through documented controls, governance processes and monitoring measures.

To assist firms in strengthening their AML/CFT frameworks, Compli-Serve offers an Independent RMCP and BRA Desktop Compliance Review Service.

Independent Assurance Through a Structured Desktop Review

This service provides an independent, desk-based assessment of an organisation’s RMCP and Business Risk Assessment against:

  • Section 42 of the Financial Intelligence Centre Act (FICA)
  • FIC Guidance Note 7A principles
  • Current AML/CFT regulatory expectations
  • Risk-based compliance practices
  • Inspection readiness considerations

The objective is not to conduct an audit or provide a compliance guarantee.

Rather, the review provides organisations with an experienced and independent assessment of whether their documentation is adequately designed, appropriately aligned and capable of withstanding regulatory scrutiny.

Why Independent Reviews Matter

Many organisations develop RMCPs internally or through external service providers but seldom undertake an independent assessment thereafter.

As a result, common challenges often emerge:

  • RMCPs that do not align with the institution’s Business Risk Assessment
  • Weak or generic risk-rating methodologies
  • Insufficient beneficial ownership controls
  • Limited sanctions and targeted financial sanctions procedures
  • Inadequate ongoing monitoring frameworks
  • Gaps in governance oversight and accountability structures
  • Documentation that appears compliant on paper but lacks practical application

An independent review helps identify these issues before they are identified during an inspection.

Scope of Review

Our structured review methodology includes:

RMCP Assessment

  • Review of RMCP adequacy against Section 42 requirements
  • Assessment of governance structures and accountability arrangements
  • Evaluation of customer due diligence measures
  • Review of sanctions and Targeted Financial Sanctions controls
  • Assessment of monitoring, reporting and record-keeping procedures
  • Review of staff awareness, training and escalation processes

Business Risk Assessment Review

  • Assessment of BRA methodology and risk identification processes
  • Review of customer, product, service, geographic and delivery channel risks
  • Evaluation of risk-rating frameworks
  • Testing alignment between identified risks and RMCP controls

Regulatory Benchmarking

  • Benchmarking against current regulatory expectations
  • Assessment of inspection readiness
  • Identification of documentation gaps and weaknesses
  • Practical recommendations for enhancement

Deliverables

Clients receive a comprehensive review package which may include:

  • Independent RMCP Adequacy Review Report
  • BRA Alignment Assessment
  • Section 42 Compliance Checklist
  • Gap Analysis Report
  • Corrective Action Plan
  • Executive and Board Summary
  • Optional Board or Risk Committee Presentation

The focus is always practical implementation and achievable remediation.

What This Service Is Not

To ensure clear expectations, this service is not:

  • A statutory audit
  • A regulatory certification
  • A guarantee of compliance
  • A guarantee against regulatory findings
  • Legal advice
  • An implementation engagement unless separately scoped

The service is designed to provide independent professional insight and practical recommendations that strengthen compliance frameworks and improve regulatory readiness.

Ideal For

This service is particularly valuable for:

  • Financial Services Providers
  • Asset Managers
  • Collective Investment Scheme Managers
  • Fund Administrators
  • Crypto Asset Service Providers
  • Trust and Corporate Service Providers
  • Accountable Institutions preparing for FIC or FSCA inspections
  • Boards seeking additional assurance regarding AML governance

A Practical Governance Tool for Boards

An RMCP is no longer simply a policy document.

Increasingly, it serves as the foundation of an institution’s AML/CFT governance framework and demonstrates how the organisation identifies, assesses, manages and mitigates financial crime risks.

An independent review provides boards, key individuals, compliance officers and senior management with valuable insight into the effectiveness and defensibility of that framework.

Service Options

Desktop Review

Suitable for smaller and less complex organisations requiring an independent documentation assessment.

Standard Review

Expanded review with detailed benchmarking, findings analysis and remediation planning.

Enhanced Review

Comprehensive multi-entity or higher-risk review engagement with board-level reporting and governance support.

The Compli-Serve Difference

Our review methodology has been refined through extensive work across financial institutions, asset managers, fund administrators, trusts and other accountable institutions.

We combine practical compliance experience with a deep understanding of regulatory expectations to provide actionable recommendations that improve governance, strengthen compliance frameworks and enhance inspection readiness.

Independent. Practical. Risk-Based. Inspection Ready.   CompliServe_Desktop_Review_Service (1)