AML audit: Practice for ZISIF15

Nikita Veremeev

24.11.2025 | 6 min read

Updated: 24.11.2025

In 2024 the global financial services market faced an unprecedented rise in fines for anti-money laundering violations: in Europe alone the total amount of sanctions exceeded €6 billion, and the average fine for financial institutions increased by 45% compared with the previous year. But the numbers are only the tip of the iceberg. Behind every fine are frozen accounts, loss of access to international payments, blocked transactions and, most importantly, severe reputational costs that can be fatal to a business.

Companies like ZISIF15, operating at the intersection of traditional and digital finance, are particularly vulnerable: their activities are under the scrutiny of regulators in the EU, Asia and the CIS, and requirements for transparency and transaction controls are tightened every year. In these circumstances AML audit becomes not just a formal procedure, but a strategic tool for protecting the business, minimizing risks and increasing investment attractiveness.

In its practice the COREDO team has repeatedly encountered situations where clients who neglected regular AML audits faced the threat of account freezes and sudden inspections by regulators. Unlike a classic financial audit, the task of an AML audit is not only to reconcile the numbers but also to identify vulnerabilities in the internal control system, verify the relevance of AML policies and procedures, assess the effectiveness of the AML program and ensure the company’s real AML compliance.

Essentially, an AML audit for ZISIF15 companies is a comprehensive review for compliance with international and local requirements in anti-money laundering and countering the financing of terrorism (CFT), including analysis of KYC processes, transaction monitoring, risk assessment and readiness to interact with regulators. Such an approach makes it possible not only to avoid fines and blocks, but also to build trusting relationships with banks, investors and partners.

AML audit for ZISIF15 in 2025

Illustration for the section «AML audit for ZISIF15 in 2025» in the article «Practice of AML audit for ZISIF15»

International standards in the field of AML compliance are constantly evolving. In 2025, the key benchmarks for ZISIF15 companies remain the FATF recommendations, as well as the EU directives: 4AMLD, 5AMLD and 6AMLD, which set standards for customer identification, transaction monitoring and reporting. In Asia and the CIS, requirements are increasingly being aligned with European and international norms, while local regulators introduce their own supervisory mechanisms.

COREDO’s practice confirms: for ZISIF15 companies it is critically important not only to have a formal AML program but also for it to be actually operational. Regulators require:

The presence and regular updating of AML policies and procedures reflecting the specifics of the business and risks.
Implementation of effective KYC procedures and beneficiary verification tools.
Continuous AML monitoring of operations and control of suspicious transactions, including cryptocurrency operations.
Preparation and storage of AML reporting (including SAR – Suspicious Activity Report) in accordance with the requirements of FATF and local regulators.
Appointment of a person responsible for AML, internal controls and regular staff training.

For ZISIF15, requirements for transparency of ownership structure, automation of monitoring and integration of RegTech solutions become especially important. In the EU and the United Kingdom the emphasis is on automated systems, eKYC and digital identity, while in Asia and the CIS it is on adapting procedures to local realities and rapid response to changes in the regulatory environment.

Company AML audit: step-by-step process

Illustration for the section 'AML audit of the company: step-by-step process' in the article 'AML audit practice for ZISIF15'

The AML audit practice for ZISIF15 companies: a step-by-step guide is not just a formal check, but an important tool for identifying vulnerabilities and improving the effectiveness of internal control. Such an audit makes it possible to timely identify gaps in the anti-money laundering system and prepare recommendations to eliminate them, based on real experience in conducting AML procedures.

Preparation for the AML audit

First step: a thorough review of KYC procedures and client Due Diligence mechanisms. COREDO’s experience shows that it is at this stage that the main vulnerabilities are revealed: outdated questionnaires, insufficient verification of beneficiaries, absence of a client’s digital profile.

Transaction monitoring and control

Modern AML audit is impossible without automation. Solutions developed at COREDO include the implementation of RegTech platforms and AI algorithms for AML monitoring of operations and AML control of transactions. This approach allows real-time detection of anomalies, conducting AML checks of cryptocurrency, building transaction graphs and applying risk scoring to evaluate suspicious addresses.

Reporting and interaction with regulators

Preparing SAR (Suspicious Activity Report): a key element of reporting. In practice, COREDO has implemented automated templates for SAR preparation, which speeds up the process and reduces the risk of errors. It is important not only to submit reports on time, but also to maintain transparent communication with regulators and be ready for unscheduled inspections and requests.

A comprehensive AML review makes it possible to identify and eliminate gaps in advance, minimizing the likelihood of fines and sanctions. In case suspicious transactions are detected: promptly initiate an internal investigation and, if necessary, freeze accounts until the circumstances are clarified.

AML audit of cryptocurrency transactions

Illustration for the section «AML audit of cryptocurrency transactions» in the article «AML audit practice for ZISIF15»

Cryptocurrency transactions require a special approach to AML checks. International studies (Chainalysis, FATF, JBA) confirm: more than 60% of money laundering cases in 2023–2024 were related to digital assets. For ZISIF15 companies, this means the need to implement specialized tools:

AML monitoring of transactions using blockchain graph analysis algorithms and risk scoring of crypto addresses.
Automated AML screening of cryptocurrency taking into account transaction specifics (mixers, privacy coins, DeFi).
Use of RegTech solutions to integrate data from external sources (sanctions lists, databases of suspicious addresses).

In one of COREDO’s cases for an EU client, a system was implemented that allows real-time detection of suspicious transactions across more than 30 blockchains, which reduced the number of false positives by 40% and helped avoid a regulatory fine.

How to scale an AML program during expansion

Illustration for the section «How to scale an AML program during expansion» in the article «AML Audit Practice for ZISIF15»

Expanding business into new markets requires adapting the AML program to the requirements of each jurisdiction. COREDO’s practice shows: there are no universal solutions, and a successful strategy is built on flexibility and deep localization.

For the EU, compliance with 6AMLD, implementation of eKYC, and automation of reporting are critical.
In Asia – consideration of national standards, integration of local registries, and staff training on the specifics of regional risks.
In the CIS – regular auditing of current procedures, updating policies, and moving from manual monitoring to automated systems.

When registering companies in Europe and Asia, the COREDO team always conducts a preliminary AML audit to identify potential gaps between corporate standards and local requirements. This approach helps avoid delays in opening bank accounts, reduce operational risks, and ensure sustainable scaling.

AML audit in international companies – best practices

Illustration for the section «AML audit in international companies - best practices» in the article «AML audit practice for ZISIF15»

Effective AML audit is built on integrating KYC and AML processes, ongoing staff training and the use of modern technologies. At COREDO we implement the following practices:

Integration of KYC/AML/KYT into a single platform, enabling monitoring of the entire customer and transaction lifecycle.
Regular AML training for staff that reflects new threats and changes in legislation.
Use of artificial intelligence and RegTech solutions to automate monitoring, transaction analysis and reporting.
Conducting stress tests and scenario modelling to assess the resilience of the AML program.

In one recent project for an international fintech company, COREDO implemented an automated anomaly detection system, which reduced internal investigation time from 5 days to 12 hours and significantly improved the quality of compliance.

How to evaluate the effectiveness of an AML program

Evaluating the effectiveness of an AML program: the key to increasing ROI and reducing operating costs. At COREDO we recommend using the following metrics:

Number of detected and prevented suspicious transactions.
Incident response time and SAR preparation speed.
Ratio of false positives to confirmed alerts.
Level of automation and integration with external data sources.
Number and quality of trained staff.

Implementing a comprehensive AML system not only reduces the likelihood of fines, but also increases trust from banks, investors and partners. In the long term, this directly affects the company’s value and its competitiveness in the international market.

Comparison of AML audits in the EU, Asia, the CIS and Africa

Region	Key requirements	Features for ZISIF15	Typical risks	Recommendations
EU	6AMLD, AMLR, AMLA	High fines, automation, eKYC	Sanctions risks, account freezes	Implement RegTech, prepare for compliance audits
Asia	FATF, local laws	Variety of requirements, increasing regulation	Money laundering risks via cryptocurrencies	Adaptation to local rules, staff training
CIS	6AMLD, AMLR	Partial eKYC implementation, manual monitoring	Lower fines, local regulators	Audit of existing procedures, policy updates
Africa	FATF, local laws	Developing regulatory framework	Money laundering risks via cryptocurrencies	Implement automated systems, training

Guide for ZISIF15 Leaders: Practical Steps

To pass an AML audit and minimize risks, I recommend the following approach:

Conduct a preliminary AML audit involving external experts to identify weaknesses.
Update KYC procedures and implement digital onboarding.
Implement automated AML systems for transaction monitoring and graph-based transaction analysis.
Appoint a person responsible for AML and internal control, and regularly train the team.
Ensure transparency of ownership structure and sources of funds.
Develop and implement procedures for preparing and submitting SARs.
Conduct regular stress tests and update AML policy in accordance with changes in legislation.

COREDO’s practice shows: a comprehensive approach to AML review not only reduces the likelihood of fines, but also helps identify vulnerabilities, improve the quality of internal control, and build a resilient business model.

How an AML audit affects a company’s strategy

In today’s environment, an AML audit is not just a regulatory requirement but a strategic tool for risk management, enhancing transparency and trust. Companies that invest in developing AML compliance gain a competitive edge: access to international markets, the trust of investors and partners, reduced costs for internal investigations, and a lower likelihood of fines.

COREDO’s implemented solutions for clients from the EU, Asia and the CIS show: a properly designed AML program not only helps prevent money laundering and the financing of terrorism, but also helps build the reputation of a responsible and reliable player in the global market. In the long term, this directly affects the value of the business, its resilience and investment appeal.

If you strive for sustainable development, transparency and risk minimization, an AML audit should become an integral part of your corporate strategy. The COREDO team is ready to share its expertise, offer tailored solutions and support your business at every stage – from registering a legal entity to building an effective AML risk management system.