What to do after a negative AML audit?

Nikita Veremeev

05.01.2026 | 6 min read

Updated: 05.01.2026

As CEO and founder of COREDO, I see every day how entrepreneurs from Europe, Asia and the CIS face a negative AML audit. This moment turns ambitious growth into a crisis: fines, reputational risks and frozen accounts. Our experience at COREDO shows that the right remediation plan after an AML audit not only corrects violations – it strengthens the business, increasing ROI from compliance and opening doors to new licenses and markets.

Over the past 9 years I have seen dozens of AML remediation projects after a negative audit. And almost always the problem is not the absence of policies, but the gap between the documents and real operational practice.

The most common mistake CEOs make is believing that an updated AML policy automatically closes the regulator’s concerns. In practice regulators look not at a PDF, but at the decision trail: who, when and on the basis of what data made decisions regarding clients and transactions.

In one project in the EU a client had 120 pages of AML policies and not a single documented rationale for EDD. This became the key trigger for the negative audit.

Imagine: your fintech startup in Estonia has just undergone an external audit under the EU AML directives, and the report identified gaps in KYC/CDD/EDD for high-risk clients from Asia. The regulator requires urgent measures, and you waste time rewriting policies manually. The COREDO team implemented something like this for a client from Singapore: we developed AML remediation in 45 days, integrating RegTech with AI for transaction monitoring. The result: zero repeat violations and a license for payment services, approved by the MAS (Monetary Authority of Singapore).

Based on our practice of interacting with regulators (MAS, DFSA, CySEC, CNB), after a negative AML audit they assess not the “perfection” of the system, but the progress of remediation.

The regulator’s key questions are always the same:

Is the root cause of the violations understood;
Has a specific responsible AML officer been appointed;
Is there control over remediation timelines;
Is the effectiveness of the new measures being measured.

Companies that immediately present a transparent remediation roadmap receive a significantly more lenient supervisory regime than those who formally “rewrite policies”.

Negative AML audit: impact on business and COREDO

Illustration for the section «Negative AML audit: impact on business and COREDO» in the article «What to do after a negative AML audit»

AML compliance failure often starts unnoticed: transaction monitoring gaps, outdated KYC procedures or weak sanctions screening. According to FATF recommendations, a risk-based approach requires constant adaptation, especially in the EU, where the 6th AML Directive strengthens oversight of crypto and fintech. COREDO’s practice confirms: 70% of negative audits are related to false-positive alerts — the system generates thousands of false triggers, disrupting the client experience and operations.

Typical causes of a negative AML audit

In more than 70% of cases a negative AML audit is not due to the absence of an AML framework as such. The causes are systemic:

overloaded transaction monitoring rules without risk-based logic;
lack of documented decision-making for EDD;
a gap between the frontline and the AML function;
outdated risk-scoring models that do not reflect the real client profile.

After an AML audit, ignoring the action plan leads to AML fines of millions of euros — recall cases in the Czech Republic and Slovakia where banks lost licenses due to AML risks. But the solution developed by COREDO focuses on proactive compliance: we conduct an AML risk assessment with Precision/Recall metrics, where Precision above 90% minimizes false alarms, and Recall catches 98% of real threats. This is not theory: for a client in Dubai we optimized the system after a DFSA audit, reducing operational risks by 40% and accelerating SAR/STR reporting.

How to properly read a negative AML audit report

A typical AML audit report always consists of four blocks: findings, root causes, regulatory expectations and remediation timeline. The mistake of most companies is working only with the findings, without addressing the root causes.

At COREDO we begin remediation with a reverse analysis: each violation is mapped to the process, the system and the specific management decision. This allows us to eliminate not the symptoms, but the architectural defects of the AML system.

Steps for remediation after an AML audit

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Developing a remediation plan after a negative AML audit is a task that requires experience. Here is the sequence we apply for international businesses in the EU, Asia and the CIS:

Immediate report analysis. We start with an internal AML audit, identifying vulnerabilities: gaps in transaction monitoring, incomplete EDD for high-risk clients, or lack of logging of AML decisions. The COREDO team records all non-compliances with EU AML directives and FATF, preparing a roadmap within 72 hours.
Appointment of an AML agent and a compliance officer. We choose an internal or external AML agent certified by ACAMS. COREDO’s practice shows: modular AML staff training (KYC updates after an audit, incident investigations) increases effectiveness by 60%. For a Cypriot client we integrated biometric KYC with Face ID, reducing verification time from 3 days to 5 minutes.
Updating AML procedures. AML policy updates toward a risk-based approach: we adapt to new EU directives, introducing AML monitoring automation through RegTech. We use AML machine learning for predictive analysis: an AI-based model predicts AML risks with 95% accuracy, integrating blockchain analysis for crypto transactions.
Implementation of RegTech and AI. After an AML compliance failure, automation is the key to scaling. RegTech AML addresses transaction monitoring gaps: for an Estonian payment platform COREDO deployed a system with automated monitoring systems, where Precision/Recall metrics reached 92%/97%. ROI? Savings of €250k per year on staff plus zero fines.

It’s important to understand: RegTech and AI are not a ‘silver bullet’. Automation only works when a risk-based logic is built beforehand.

In COREDO projects we first optimize rules and risk scoring manually, and only then automate. This approach prevents a company from scaling errors instead of controls.

KYC updates after the audit and sanctions screening. We strengthen CDD/EDD, adding vendor Due Diligence for partners. In Singapore we helped a client pass a MAS audit by implementing real-time screening across 500+ sanctions lists — AML reputational risks dropped to zero.
Testing and reporting. We conduct an internal compliance audit, simulating an external AML inspection. We prepare reports on suspicious transactions and cooperate with regulators, minimizing the long-term consequences of AML fines.

This plan is not a template, but a custom solution. For a Slovak fintech after a negative audit we scaled AML compliance for growth into Asia: AI integration to prevent repeat AML risks plus adaptive AML policies secured a forex license without further modifications.

How COREDO ensures ROI

Illustration for the section 'How COREDO ensures ROI' in the article 'What to do after a negative AML audit'

The ROI calculation for investments in AML systems after a fine is simple: savings on fines (average: €1–5M) + increased revenue from faster onboarding. Our experience: a client in the UK returned 3x the investment in a year thanks to scaling AML systems. AML customer experience improved: false positives fell by 75%, customers remain loyal.

When remediation doesn’t save the business

In some cases a negative AML audit reveals not operational but strategic problems. If the business model was originally built around high-risk flows without economic substance, remediation becomes a temporary measure. In such situations we recommend restructuring, changing jurisdiction, or ceasing licensed activities. These are difficult decisions, but they are what allow the business to be preserved in the long term.

Do negative AML audits affect reputation in the CIS and Asia? Absolutely: investors pull out, licenses are blocked. But managing reputational risks after an AML failure through a transparent compliance culture changes the trajectory. COREDO’s practice confirms: partnership with AML providers and AML incident management build trust with regulators.

Real cases of registration and support

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Registration of legal entities abroad has been our foundation since 2016. In Cyprus we opened a company for an EU startup in 7 days, immediately providing substance (office, staff) according to the new 2025 rules. Then we obtained a CySEC crypto license, integrating AML compliance with biometric verification.

In Dubai for an Asian holding: Mainland registration + DFSA payments license. After the initial audit we introduced a deep internal AML audit, eliminating KYC deficiencies – the business scaled without disruptions.

In Estonia: e-Residency + EMI license: the COREDO team carried out an AML risk assessment, implementing AI in AML for transaction monitoring. The client avoided AML fines while expanding into the CIS.

These cases demonstrate comprehensiveness: from registration to post-audit AML actions, including staff training after a negative AML report and optimization of Precision/Recall in AML alerts.

Financial licenses and compliance with COREDO

Illustration for the section «Financial licenses and compliance with COREDO» in the article «What to do after a negative AML audit»

obtaining licenses (crypto, banking, forex, payments) requires perfect AML. In the Czech Republic we helped with a CNB license, updating the AML policy to align with EU AML directives. In Singapore: MAS for forex, with automated AML monitoring based on machine learning.

Is it worth investing in AI after a negative report? Yes, if the goal is proactive compliance. We estimate payback in 6-9 months due to reduced AML operational risks and flexible AML systems for growth.

CEO checklist after a negative AML audit

If a company receives a negative AML audit, the CEO must answer five questions:

Do we understand the root cause, not just the wording of the report?
Has a specific person been assigned responsibility for remediation?
Are there measurable KPIs for AML effectiveness?
Can we show the decision trail to the regulator?
Do we understand how AML affects business growth?

Negative answers to these questions are a direct indicator of the need for urgent remediation.

COREDO as a strategic partner

A negative AML audit is not the end but the start of a transformation. The COREDO team offers proven tools: from steps to remediate vulnerabilities after an AML review to implementing RegTech after an AML compliance failure. We save your time, ensure transparency, and support you at every stage: from registration in Serbia or the UAE to licenses in the EU.

Contact us: together we’ll turn risks into a competitive advantage. Your business deserves a reliable partner with 9 years of experience in Europe, Asia and the CIS.