17 January 2026
When an AML file review should pause product launches
Launching a new lending corridor while due-diligence samples still show incomplete source-of-funds notes invites avoidable findings.
Launch pressure is real when a new lending or remittance corridor sits behind a marketing calendar. Still, opening that corridor while beneficial-ownership notes remain incomplete is an invitation for findings that stick longer than any launch delay.
Before go-live, pull a risk-weighted sample of files — not only the tidy ones prepared for training. Look for source-of-funds narratives that stop at “salary,” missing screening hits that were never dispositioned, and escalation memos that lack a named decision-maker.
If sampling shows a pattern, pause the corridor. Two weeks spent closing file gaps is usually cheaper than a licence condition that freezes the product after launch. Tell sales the reason in plain language: incomplete diligence files create regulatory and reputational cost that outlasts a campaign window.
Our AML programme review is designed for this moment — file sampling first, narrative later — so leadership can decide whether to hold or proceed with eyes open.