Regulatory update
5 most common AML compliance failures found during HMRC inspections
Mehmood Rajoka9 min readMay 2026
In brief: The five most common AML compliance failures are: no current firm-wide risk assessment; incomplete CDD records; no dated screening evidence; an undocumented MLRO; and staff training that was never recorded.
Key points
- Missing or outdated firm-wide risk assessment
- Incomplete CDD records — expired documents, missing beneficial owners
- No dated evidence of PEP and sanctions screening
- MLRO not formally appointed or documented
- Staff training happened but no records were kept
The five most common AML failures identified by HMRC when inspecting UK accountancy practices — and how to fix each one.