Enigma Consulting can assist firms in fulfilling the internal control function. The objective is to carry out a full and comprehensive internal audit cycle each year, which can be structured in multiple tranches.

The Enigma Consulting’s auditors are practice-oriented and pragmatic, and proceed whilst taking into account the phase in which the firm to be audited finds itself. Enigma Consulting will operate in an efficient manner and will consciously seek coordination with the activities of the second line (the compliance team) to avoid any unwarranted duplication of activities.

Geert Blom
Geert Blom
Senior Legal Adviseur

Audit process

The audit process that Enigma Consulting employs is depicted in the following graphic:

Internal audit

Yearly audit-cycle


As can be observed, the audit year plan constitutes the central document for planning the operational audit activities. Themes that will be explored in this plan are:

Internal audit themes

Review of ongoing customer monitoring processes, KYC, PEPs , high risk. Review of current transaction monitoring systems.

Ensure compliancy with financial crime regulations, guidance from the regulators and third party guidance.

Review financial crime quality assurance and quality control program (CDD, customer risk rating, customer screening, ongoing monitoring and transaction monitoring.

Review the application of the risk-based approach by evaluating policies, procedures and CDD, risk appetite and the risk assessment process.

Review the reporting processes, including management information, unusual transaction report and financial crime incident reporting.

Review the company’s risk management structure and CDD to ensure regulatory compliance and progress against previous audit recommendations.

Review and perform file reviews of the company’s customer screening process.

Review training and awareness program. Ensure all teams are trained sufficiently . Determine level of awareness within financial crime risks inherent to the company.

Review the current financial crime governance and team structure at the company to identify gaps and deficiencies.

Other Risk & Compliance Services

Risk & Compliance
Licence applications
Payments Risk
Compliance Officer
Operational Risk
Licence Online Games of Chance

Our Risk & Compliance Experts

Erik van der Leer

Geert Blom

Senior Legal Adviseur
Jaap Jan de Jong

Executive Consultant
Lex van Beurden

Maarten van Denzen

Senior Legal Consultant
Peter Mulders

Executive Consultant
Roxane van der Laan

Executive Consultant
Thim Donkervoort

Legal Consultant