Compliance Health score

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

14 factors, each worth a fixed number of points (120 in all). The score is the points you have as a percentage of 120. Traffic light: green at 85% or more, amber at 60% or more, else red.

#	Factor	Points	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 19
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(1)(c)
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	n/a
13	AML hits dispositioned	10	MLR reg 28(11)
14	Firm-wide risk assessment current	10	MLR reg 18(4)

Firm-wide risk assessment current gives full points while your latest signed firm-wide risk assessment is in date, half once it is overdue, and none if you have never signed one off. It must be reviewed at least once a year. See Firm-wide risk assessment.

Sole practitioners with no staff

AMLGAS 3.3: a sole practitioner with no relevant employees (nobody else, including part-time staff and contractors, working on your services) need not appoint an MLRO or a compliance officer, or arrange an independent review, unless their supervisor requires it. The firm owner can say so in Settings → AML Compliance → MLRO appointments → Governance. While it applies, the MLRO, staff training and independent audit factors show "Not required" and score full points. It only applies while you are the firm's only member: invite anyone and the normal expectations return.

How to improve it (in order of impact)

Largest single wins first:

1. Appoint an MLRO: +15 pts. Single click in Settings → AML Compliance → MLRO Appointment.
2. Publish your PCP: +10 pts. Settings → AML Compliance → Policies, Controls & Procedures → Publish first version.
3. Score every client: proportional up to +10 pts. Open each client → Risk assessment tab → complete.
4. Get staff to acknowledge the PCP: proportional up to +10 pts. Banner appears for staff on their dashboard when a new PCP is published.
5. Log AML training: proportional up to +10 pts. Settings → AML Compliance → Staff AML Training Register.
6. Arrange an independent audit: +10 pts. MLR 2017 reg 21(1)(c) and AMLGAS 3.6.25 require regular reviews by someone independent of your AML function, proportionate to your size. A review by your own MLRO scores 5, not 10. Record who did it in Settings → AML Compliance → Audit reports.
7. Sign off your firm-wide risk assessment: +10 pts. Settings → Risk.

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.