At a glance
A clear assignment defines the object, period, sample, review criteria and written deliverable format.
In this article 2 min read
Start with the activity category
Rosfinmonitoring states that internal control rules are developed and approved by the organisation under the established procedure. External consultancy support helps prepare or review documents. The assignment first requires identifying the organisation's category and the requirements against which the agreed scope will be assessed. [1]
Identify the review object
A review may cover a particular rules version, an agreed sample of client materials, allocation of roles or performance of a specific procedure. These tasks differ in their data and effort requirements. The phrase “check everything” defines neither examination depth nor the provider's responsibility boundaries.
Record the period and sample
The assignment states the period, number of documents or files, selection basis and excluded areas. A sample review does not automatically support a finding about every client of the organisation. If the sample needs expanding during the work, its scope, timing and fee are agreed separately.
Determine data-handling arrangements
The necessary information, lawful transfer basis and access method are established in advance. Rules, forms and an anonymised process structure suffice for many initial tasks. Transfer of full client data should serve a specific review purpose, rather than the convenience of a bulk export.
Agree the form of findings
A useful report connects each finding to the reviewed document, explains its basis and proposes a corrective action. The agreed plan determines priority and implementation responsibility. Preparing the report alone does not implement changes, appoint a special AML/CFT officer or mean that the service provider assumes that officer's functions.
Official sources
Sources checked on 24 October 2026. Practical recommendations on preparing materials are provided by the AML Expert editorial team. The procedure for a specific case depends on the documents and the applicable basis.