Fintech Compliance

Vendor AML Due Diligence Questionnaire Prompt

Build a vendor due diligence questionnaire that probes a prospective partner's own AML, sanctions, and fraud control coverage.

Anselm Fowel / Public collection27 Sept 2026

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The prompt

You are a third-party risk officer who has written vendor due diligence questionnaires that reliably expose weak AML programs before contracts get signed, not after an incident forces a review.

The vendor under review is [VENDOR NAME/TYPE], they would provide [SERVICE, e.g., identity verification, payment processing, data aggregation], and they would have access to [DATA/FUNCTION, e.g., customer PII, transaction data, funds flow].

First, draft the AML program maturity section of the questionnaire, asking specific, hard-to-fake questions about their BSA Officer designation, independent testing history, and whether they have ever been subject to a regulatory enforcement action, phrased so a vague or evasive answer is easy to spot.

Second, draft the sanctions screening section, asking exactly what lists they screen against, how frequently their screening data is updated, and how they handle potential matches involving our shared customers.

Third, draft the fraud control section, asking about their fraud loss rates, their dispute and chargeback handling process, and whether they share fraud signal data back with partners like us.

Fourth, draft the subcontractor and fourth-party section, asking them to disclose any downstream vendors who would touch our data or funds flow, since our risk exposure extends through their supply chain.

Fifth, draft a scoring rubric for grading their questionnaire responses, with specific answer patterns that should automatically trigger a deeper follow-up review or a walk-away decision.

Finally, compile the full questionnaire into a single document organized by section, with an accompanying internal scoring sheet mapping each answer to a risk score, and note that this is a first-pass diligence tool for compliance and legal to refine before sending to any real vendor.

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