AML compliance core guides

Use these guides to translate AML regulations, programmes, reforms, and control concepts into practical firm workflows.

What Regulation 19 requires

Written policies, controls and procedures proportionate to the firm's size and the risks it identified. The proportionality point matters: a sole practitioner and a fifty-partner firm are held to the same standard of having considered the risk, not to the same volume of documentation.

Why policies fail inspection

Usually because they describe a process the firm does not follow. A short policy that matches practice survives scrutiny better than a long one adapted from a template, because the inspection tests the gap between the two.