Notes
Short notes from financial crime audits for payment services — written for MLRO, fraud, and operations partners.
Monitoring rules without owners create quiet risk
Payment teams often tune thresholds without recording who approved the change — and that gap shows up first in financial crime audits.
Screening overrides need a paper trail
A cleared sanctions hit without recorded rationale is a finding waiting to happen — especially for payment institutions under partner scrutiny.
Fraud controls and AML controls are not the same audit
Mixing fraud loss metrics with money-laundering control evidence confuses boards — and weakens both programmes in payment services.