Compliance Health score
In brief: How the 12-factor score works and what each factor measures.
The headline metric on your dashboard. MLR 2017 reg 21 makes the firm's senior management responsible for the AML programme — this score is the single number that summarises whether you're meeting that responsibility.
How the score works
12 factors, each worth a fixed weight. Sum is the score out of 100. Traffic light: green ≥ 85, amber ≥ 60, else red.
| # | Factor | Weight | Cites |
|---|---|---|---|
| 1 | MLRO appointed | 15 | MLR reg 21 + POCA s.330 |
| 2 | Active PCP published | 10 | MLR reg 19 |
| 3 | PCP review within cadence | 5 | MLR reg 18(6) |
| 4 | Staff PCP acknowledgements | 10 | MLR reg 19(3) |
| 5 | Staff AML training current | 10 | MLR reg 24 |
| 6 | Independent audit ≤ 12 months | 10 | MLR reg 21 |
| 7 | No overdue risk reassessments | 10 | MLR reg 28(11) |
| 8 | No stale draft SARs | 5 | POCA s.330 |
| 9 | No stale internal SARs | 5 | POCA s.330 / AMLGAS ch.6 |
| 10 | No stale material-change flags | 5 | MLR reg 28(11)(b) |
| 11 | All clients risk-scored | 10 | MLR reg 28(2) |
| 12 | All clients have compliance status | 5 | — |
How to improve it (in order of impact)
Largest single wins first:
- Appoint an MLRO — +15 pts. Single click in Settings → AML Compliance → MLRO Appointment.
- Publish your PCP — +10 pts. Settings → AML Compliance → Policies, Controls & Procedures → Publish first version.
- Score every client — proportional up to +10 pts. Open each client → Risk assessment tab → complete.
- Get staff to acknowledge the PCP — proportional up to +10 pts. Banner appears for staff on their dashboard when a new PCP is published.
- Log AML training — proportional up to +10 pts. Settings → AML Compliance → Staff AML Training Register.
- Arrange an independent audit — +10 pts. Required by MLR reg 21 for firms with 10+ relevant staff.
Counterparts to this card
- The MLRO Queue is the operational inverse — same data shown as "things to action today" rather than "are we compliant?"
- The Client Compliance Status card on each client profile is the per-client version of the same scoring.
Together these three views are called the compliance trinity.
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