verist (n.) — from the Latin verus, “true”: one who depicts things exactly as they are.
Verist reviews AML policies, CDD files, MLRO reporting and remediation plans for Irish regulated firms — funds and ICAVs, management companies, MiFID firms, payment and e-money institutions, CASPs and Schedule 2 entities. Fixed fees, agreed in writing before work begins.
We hold no PCF appointments, no MLRO or compliance officer roles, and no directorships at any client. We do not draft the documents we review, and we will not review a policy, plan or programme that this practice designed within the preceding twenty-four months.
And within the practice: no opinion is issued on the judgement of one person alone.
Five products, one discipline. Most clients start small and annual; every engagement is fixed-fee and dual-signed.
The board’s principal annual assurance artefact, checked against the EBA’s stated content standard and the Central Bank’s published expectations — coverage, quantitative MI, independent judgement, prior findings tracked to closure. Delivered as a coverage matrix, the gaps, and the questions the board should be asking.
Obligation-by-obligation coverage against section 54 of the CJA 2010; whether the suite is entity-specific or a group template; whether operational procedures exist beneath the policies; and readiness against AMLR Article 9, which requires re-approval of every policy suite before July 2027. Findings and required outcomes — never drafted text.
A risk-stratified sample tested against your own procedures and against CJA 2010 Part 4 — for quality, not just completeness. The delegate-oversight variant tests your administrator’s or outsourced provider’s files and procedures: the sample testing the Central Bank expects of every firm that delegates.
The full engagement: twelve domains from governance to prior-findings closure, tested on design and operating effectiveness, assessed for outcomes rather than procedure-adherence alone. This is the review contemplated by AMLR Article 9(2)(b) — the “external expert” testing internal policies, procedures and controls.
Before a remediation plan — or a response to a Central Bank Risk Mitigation Programme — is committed, an independent read on whether it will survive scrutiny: root cause, sequencing, interim risk mitigation, and a validation step at the end.
From the Latin verus — true. Verism was the style of Roman Republican portraiture: where Greek sculptors idealised their subjects, the verists carved every line, scar and wrinkle, because in that culture the unflattered likeness was the credible one.
A verist depicts things exactly as they are. That is the whole of our method — findings reported at their true severity, inflated in neither direction, whether or not the picture is comfortable. A report of four hundred findings, of which three hundred and eighty are filing-cabinet issues, is not assurance; it is noise. We do not write that report.
The unflattered likeness is the credible one.
No regulator prescribes what an AML review contains — so the reviewer’s method is what makes the opinion worth having. Ours is documented, citable, and shared with every client before work begins.
Twelve domains, tested on design and operating effectiveness — anchored on the sources supervisors themselves use: the Central Bank’s Guidelines and sectoral bulletins, EBA/GL/2022/05, the FFIEC independent-testing standard, JMLSG Part I, FATF Recommendation 18 and the Wolfsberg Principles for Auditing for Effectiveness.
Sampling you can defend. No regulator states a minimum sample size — anyone who claims one is selling a checklist. We stratify by risk rating, product, channel, vintage and onboarding route; over-weight high-risk and EDD files; and define in advance the defect rate at which sampling stops and the finding becomes “this control is not operating.”
The four-eyes control our clients apply daily, applied to ourselves.
A named senior practitioner — no juniors, no leveraged pyramid. Named in the report; signs the opinion.
Took no part in the engagement. Reviews scope, sample design, findings and severity ratings — with authority to change the outcome, and a veto on issue.
Both practitioners named in the report; both sign-offs evidenced in the workpapers your auditors — and the Central Bank — can inspect.
of Irish firms expect full compliance with the new EU AML rules by July 2027 — PwC EMEA survey, Jul 2026
have completed both a detailed regulatory analysis and an impact assessment — PwC, Jul 2026
of outsourcing firms maintained full oversight of delegated onboarding — FCA multi-firm review, Jul 2026
“In general, Firms did not demonstrate that they had comprehensive assurance testing programmes in place to ensure effective and independent testing of the AML/CFT/FS framework.”Central Bank of Ireland · Nov 2021
Verist was founded by a group of AML and compliance practitioners with [X–Y] years each in Irish and international financial services, across [banking, funds, payments, MLRO and Head of Compliance roles at …]. There are no juniors: every engagement is performed by a named senior lead and reviewed by a named concurring reviewer who took no part in the work.
Fees are fixed and agreed in writing before work begins. Scope, sample design, evidence standards, the finding classification above and both named practitioners are set out in the engagement letter — so the board knows exactly what the opinion covers, and who stands behind it, before it is commissioned.
Quoted after a short scoping call, fixed in writing before work begins. No variation without a written amendment.
A minimum of two senior practitioners on every work item; the concurring reviewer is named in the report and signs off before issue.
Your firm, your auditors and the Central Bank receive access rights over our records for the engagement — accepted as standard.
We advise and opine. The decision to file an STR, close a relationship or restrict a transaction is always, and only, yours.