Not every vendor needs a governance process. Start by mapping all active third-party relationships and determining which require formal oversight.

Vendor approval should not depend on informal conversations. You need consistency — who approves, who is accountable, who is informed.

Before onboarding, capture the minimum information proving risk was understood. If you cannot explain why a vendor is safe, you are not ready to approve them.

Regulators care about outcomes. If a vendor fails, leadership must know quickly.

Define who owns risk across each domain, how often they report, and what triggers escalation to the board.

Define thresholds the board approves. When these are breached, management is required to escalate — not decide alone.

Metrics boards should see every quarter. Risk level and commentary force management to interpret — not just report numbers.

Directors should be prepared to answer these questions directly and confidently. Use this table to assign who answers what and draft talking points before the exam.

Map your fraud exposure by typology and product. Likelihood and impact ratings drive where you invest in controls.

For each fraud type, map what you prevent versus what you detect. Gaps belong in your remediation roadmap.

Set thresholds before something goes wrong. These become the basis for escalation and board reporting.

Fintechs often deploy models without distinguishing between low-impact automation and customer-impacting decision systems. Map every model and flag which require formal governance.

Governance must define who approves new models and model changes. A Model Risk Committee with a standing cadence is the minimum bar.

Before deployment, document that risk was understood and mitigated. This is the evidence package you'll need during exams.

Models degrade. Data shifts. Set these thresholds before deployment so escalation is automatic, not reactive.

Teams get into trouble when changes are treated as routine engineering work even when they alter customer outcomes or regulatory exposure. Start by defining what you govern.

Governance works when it is simple: clear owners, predictable review cadence, documented decisions. You do not need a heavyweight process — you need consistent expectations.

Before launch, capture the minimum set of information that proves you understood risk and made an informed decision.

Many findings come from weak change control. Use this for every material change — incomplete testing and missing documentation become liabilities during reviews.

Regulators and bank partners care about outcomes. If customers are harmed or controls break, leadership is expected to know quickly and act.

Document what your AML program covers today. If you cannot explain your scope in one page, your program is likely too informal or too fragmented.

Most AML failures happen in handoffs. Mapping ownership makes gaps obvious — and defensible when regulators ask.

Define what "good onboarding" looks like for your business model. Clear enough that two different reviewers reach similar outcomes.

Metrics that show risk and execution quality — not vanity numbers. Keep this to one page for leadership.

Score each statement 1–5. (1 = not in place, 3 = partially documented, 5 = fully implemented and operating effectively.) Be candid — the purpose is to find gaps before regulators do.

Follow these steps in order. Assign owners to each action — exam readiness is not a compliance-only exercise.

Organize key materials into a structured folder so documents can be accessed quickly. Assign an owner and confirm the status of each item before exam day.

Communication discipline is critical during exams. Assign roles and define how your team responds to every regulator request.