Fintech Risk Audit · 2025
Three cut-off failures hiding in plain sight
A domestic remittance firm faced renewal of its settlement sponsorship. Internal policy looked complete, yet Monday reconciliation breaks had become routine. Clearwater spent the first week mapping weekend cut-offs against the partner bank’s holiday calendar and sampling twenty exception tickets.
Findings named three operational gaps: an unowned holiday override, cloned disposition notes on high-value alerts, and a beneficial-ownership refresh rule that had never been tested on small-business customers. The board funded remediation before the bank questionnaire was filed.
Constraint noted by the client
Evidence exports took longer than planned because historical alert archives sat with a vendor. The audit calendar slipped six days; the memorandum still arrived ahead of the bank’s deadline.