Independent Money Laundering Audits for Accountants, Estate Agents, Financial Services and other regulated businesses

The regulators are serious about AML and many firms are not compliant. Don’t get caught out.

Why you need to do it

An independent audit function is a requirement of Regulation 21 of the Money Laundering Regulations 2017. Quite simply, if you get anti-money laundering compliance wrong you could commit an offence. Business owners have gone to prison. Fines can be imposed for failures, and the regulators are taking a tough line on firms in breach. As dedicated compliance professionals, we can guarantee expertise and full independence.

Doing it yourself

You can do a Regulation 21 independent audit ‘in house’, and do not have to get external advice. The audit must be carried out by someone who is not policy-writer, but who has a deep understanding of the Money Laundering Regulations. Our free comprehensive ‘DIY’ template is available to download to get you started. Do take care not to become overly reliant on templates, which the regulators see as a risk.

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Why doing it yourself is difficult

Auditing is very time consuming which eats into your earning capacity and income streams. Your time might be better spent elsewhere in the business.
Even with the best of intentions, auditing projects often get put to the bottom of the priority pile.
It is also notoriously hard to find someone internally who is not ‘marking their own work’.
The stakes could not be higher. Keeping the audit could be a false economy.

Our Unique Solution

Desktop review

We review your key AML documentation, applying the same criteria as the regulators to your firm-wide risk assessment, policies & procedures, file risk assessments.

Interviews

Next, we meet remotely with the firm’s Money Laundering Compliance Officer and Reporting Officer to get a deeper understanding of your systems and controls. Ideally, we will also speak with your team to find out what actually happens in practice.

File reviews

Our independent auditor will then remotely review a selection of live and closed files. We will be looking for compliance with your policies, appropriate risk assessment and adequate client due diligence.

Report and recommendations

The traffic light audit report will show if your policies, controls and procedures are adequate in the light of your risk assessment and whether they are working as they are intended to. We will then provide recommendations for improvement, where necessary.

Debrief meeting

To finish off the audit, we will meet with you to go through the report and recommendations. We suggest that a representative from the Board or Partnership is present so that the importance of AML compliance is fed through to the highest level.