CDD engagement
Onboarding File Sampling
Structured sampling of customer files to test whether CDD and EDD steps were completed as written—not only as designed.
What we deliver
Auditors draw a risk-weighted sample across retail, SME, and higher-risk cohorts. Each file is scored for identity evidence, beneficial ownership, source-of-funds notes, and timely refresh. You receive a quality scorecard and coaching notes for case handlers.
Who this fits
MLROs, compliance directors, and operations leads at Hong Kong fintech firms preparing for thematic CDD reviews, licence applications, or internal assurance over onboarding and monitoring.
How we work
Remote and on-site sessions from our Tsuen Wan studio. File access and sampling periods are agreed in writing before fieldwork starts. See the full engagement process.