An AML reality check

Two out of three firms inspected by the SRA in 2022-23 were either partially or non-compliant, which explains the rising regulatory scrutiny and larger fines being issued.

In November 2023, leading South-West firm Ashfords was hit with a six-figure AML penalty. Compliance teams missed glaring warning signs, including:

✔️ Unclear source of funds for multimillion-pound transactions
✔️ Links to potentially sanctioned entities
✔️ Lack of due diligence on third parties loaning money

With huge penalties and reputational damage at stake, you can’t afford to drop the ball on AML compliance. 

You might already be using an online AML solution that checks your clients’ identity and data. It’s a good start. But it’s not enough to pass an inspection.

These are the five things your AML provider should be offering to keep you fully compliant:

1. Training on all areas of AML

All employees who work with clients, handle client onboarding, transactions or record keeping need to fully understand AML as a whole, not just the product they’re using, including:

Ongoing refresher training needs to be annual (at least), to keep their knowledge current. You also need detailed records of all training completed, including assessment results.

2. AML documentation

The AML documents you create must be suitable to your firm. You must mould and flex any template structures used and keep them in an easily adjustable and distributable format along with a full audit trail of changes.

These documents must be tailored to the risks presented by the services you offer, markets you works in and clients you work with. Update all these documents annually or when the situation changes.

3. Client Due Diligence (CDD)

This is where your ID checks come in. But that’s not all for CDD. You also need the tools to:

Your business must collect this information before starting work with a client. Even if it’s an existing client embarking on a new transaction with you.

4. Records of all your AML

Your records are your proof of AML compliance. You need to be able to create and store copies of:

If your supervisor or law enforcement come knocking, they’ll expect to see written evidence of all your AML activities.

5. Regular updates

All your AML needs to be kept up-to-date, so you’re aligned with current laws and best practices. Any provider should prompt you to regularly review and update:

The AMLCC platform provides your business with all the necessary tools to everything above, and more. Allowing it to stay up to date with its AML and comply with the regulations.