HMRC AML Audit Preparation Checklist
For: UK accountancy practices preparing for an HMRC AML supervision visit.
A step-by-step checklist to prepare for an HMRC AML supervision visit — covering the 8 areas HMRC checks and what evidence to have ready.
How to use this template
Review your AML policy
Check it is current, signed, and reflects actual procedures — not a generic template.
Update your firm-wide risk assessment
Confirm it covers your current client base and has been reviewed in the last 12 months.
Audit CDD records
Check 10-20 client records at random for complete identity evidence, screening results, and risk decisions.
Verify screening evidence
Confirm every client has a dated, documented PEP and sanctions screen on record.
Confirm MLRO documentation
Verify the MLRO is formally appointed and named in the AML policy with current contact details.
Gather training records
Locate evidence of AML training for all relevant staff — dates, content, attendees.