ID verification, screening, source of funds tools: all controls, none of them documented like one. What a proper RegTech risk assessment looks like, and where to start.
Eloise Butterworth · 5 October 2026 · a four-minute read
I've lost count of the audits where someone confidently tells me what their tech product does or doesn't do, and I know they're wrong. They aren't being dishonest. Nobody ever wrote it down.
My view: if you can't evidence what a product does against your risks, you don't have a control. You have a hope.
In the firms I audit, most use at least one tech product and many use several: ID verification, screening, source of funds. They're all there to reduce the risks your firm faces and to drive efficiency.
Those risks should already be in your firm-wide risk assessment, with real data behind customer, geographic, service, transaction and delivery channel risk. So where does it say what each product does about each risk? In too many firms, nowhere.
Not all tech vendors are equal. And too often, firms tell me that the vendor told them it was OK. That isn't their call. You cannot outsource your legal and regulatory obligations to your vendors. It's on you to know and understand what your tech does, and its limitations. A good tech vendor will make that clear to you.
One per product. It doesn't need to be fancy, but it does need to be real:
Look at integration with your practice, case and document management systems. Look at emerging risks too: impersonation fraud, synthetic identities, and misuse of the platform itself. The SRA's August 2026 sectoral risk assessment update puts more weight on technology and AI misuse, so your documents should keep pace.
The legwork is real, and I won't pretend otherwise. It isn't one-and-done either, and that's the point: it repays the effort many times over.
Things keep moving: national and sectoral risk assessments, the sanctions list, and the high-risk country definitions, which were redefined from 30 June 2026. A living assessment lets you see what changed and whether your tech kept up. It also shows where your tech stack has holes, and it makes horizon scanning far easier.
Pick the product you rely on most. Write down what you believe it does. Then check it against what it actually does. If there's a gap, better you find it than a regulator.
This is exactly what I do with firms at All Things Risk, but do the first one yourself. You'll learn more than any pitch will tell you.
No pitch, no jargon, nothing open-ended. Email eloise@itsallthingsrisk.com, find All Things Risk on LinkedIn, or start with a fifteen-minute call.
Let's talk