AML Compliance reviews – the 4 situations

You are in one of 4 situations with respect to a supervisor’s AML Compliance Review:-

Here we give some brief do’s and don’ts for each of these situations.

1 You are not scheduled for a review and are not expecting one

Lucky you!  However you will be subject a review sooner or later and there are things you can sensibly do now to make that a less painful process.


  • Ensure that you have an appropriate Policies & Procedures document and a Firm-Wide Risk Assessment, and there is a note of annual reviews of, and amendments to, them
  • Check that the details held by your supervisory body about the firm and its officers are up to date and correct
  • Ensure that relevant staff have received money laundering training and there is a record of that having been completed
  • Carry out some test checks of your records of Client Due Diligence and Risk Assessments for individual clients to ensure that the firm’s policies & procedures are being implemented properly
  • Ensure that all the work which the firm is doing is within the terms of any authorisation required from your supervisory body
  • Maintain copies of any Disclosure and Barring Service checks on the firm’s beneficial owners, officers and managers and the annual fit and proper confirmations from relevant staff members
  • Consider whether arranging an external AML Compliance review now might be beneficial.


  • Just ignore AML compliance as it is not currently an issue.

2 You are at some stage in the review process

You may have received an initial questionnaire or been asked to supply copies of some relevant documents. 


  • Respond promptly to enquiries from the reviewer (even if only to acknowledge receipt of correspondence)
  • Ensure that the information you are supplying to the reviewer is scrupulously accurate and complete
  • If you are invited to select documents relating to clients for submission to the reviewer, select those clients thoughtfully and review the documents before submitting them; provide additional explanations of these documents to the reviewer if that would be helpful
  • Keep a copy of everything you submit (or request a copy from your supervisory body if you do not have a copy)
  • If you are not confident that your AML procedures are fully satisfactory, consider obtaining external assistance before responding to the reviewer.


  • Backdate or falsify any documents submitted for review
  • Try to fob-off the reviewer with incomplete or time-wasting responses.

3 A review was recently completed & you have some tasks before your next review

You may have received confirmation that the review process has been completed with a description of some issues which you are requested to address before the next scheduled review (which is likely to be some years off). 


  • Promptly acknowledge receipt of that confirmation
  • Ensure that those issues are properly and promptly addressed – they will undoubtedly be checked at the next review.


  • Allow your successful procedures to fall into disuse.

4 A review was recently completed & you are required to take urgent remedial action

You may have received a schedule listing significant AML Compliance failings which you are required to address within 30 days, together with additional points to be addressed before the next scheduled review. 


  • Promptly acknowledge receipt of that correspondence
  • If you think you are going to require longer than 30 days, contact the reviewer and ask for the time you will need (do this well before the time limit expires)
  • Consider carefully whether obtaining external assistance will help you to deal with this situation, particularly if you are not confident of your understanding of AML requirements, the reviewer has indicated that disciplinary proceedings are a possibility, or you consider the reviewer’s comments are unfair or unreasonable
  • Stand back and consider whether the firm’s whole approach to AML Compliance needs to be re-thought, including your firm’s use (or non-use) of AML Compliance software
  • Carefully study the reviewer’s criticisms and address them fully in your response including, if appropriate, submitting revised versions of documents such as Policies & Procedures, Firm-wide Risk Assessment and, in relation to individual clients reviewed, CDD and risk assessments
  • Ensure that your response to the reviewer’s comments is factually scrupulously accurate.


  • Delay in responding to the review
  • In your response, criticise the reviewer’s approach or lack of understanding of your practice (instead send the reviewer additional information to be considered).

Whichever of these situations you may be in, if you think that you may not have sufficient documentation to satisfy your supervisor to a satisfactory standard, or would simply like to discuss your firm’s AML compliance, then please contact us now.

David Winch MLRO support services ltd