Briefing · 4 min
The readiness assessment, in three tiers
MAVYN Team · 1 min read · 28 September 2026
A short MAVYN framework for benchmarking AML, sanctions and conduct programmes against what an inspection actually tests.
Not all compliance programmes are created equal. Our three-tier framework helps firms understand where they stand — and what it takes to move up.
Tier 1: Foundational. Policies exist, basic screening is in place, training happens annually. This meets minimum requirements but won't withstand detailed scrutiny.
Tier 2: Defensible. Risk assessments drive controls, monitoring is tuned to actual typologies, evidence is organised and retrievable. This is where most inspections pass.
Tier 3: Exemplary. Proactive risk identification, real-time monitoring, board-level engagement, and continuous improvement. This is where regulators hold you up as an example.
Most firms sit between Tier 1 and Tier 2. The gap is usually not resources — it's discipline and documentation.