19 February 2026
Mapping policy claims before a Hong Kong fintech review
A practical way to inventory what your policies claim will happen — then prove each claim with a control and an owner.
Reviewers rarely ask whether you have a policy. They ask how you know it works. A control-to-policy map answers that question without drowning the room in binders.
Start with material claims only: onboarding checks, transaction monitoring handoffs, complaint escalations, outsourcing oversight, and incident reporting. For each claim, name the control, the system of record, the owner, and the last time evidence was sampled.
Orphaned claims — language with no control — and orphaned controls — procedures with no policy home — both matter. Closing them before a review is cheaper than explaining them during one. Keep the map versioned; it becomes the spine of your next effectiveness audit.