What do we find on proactive AML monitoring reviews
We present our most common findings for the three stages of customer due diligence, including our assessment of how well firms perform each stage. We also explain some of the themes we see around non-compliant firms.
Updating customer due diligence
The most common finding from our 2024/25 AML monitoring reviews related to updating customer due diligence. Where we made this finding, firms were not performing, and updating, their customer due diligence throughout the duration of the client relationship.
Reporting discrepancies in PSC register
A person with significant control (PSC) is someone who owns or controls a company. If firms identify a discrepancy between the information they gather while carrying out their regulatory obligations on their corporate clients and the information their client has provided on the PSC register, they must report that discrepancy to Companies House or HMRC. We find that firms do not have the required policies and procedures in place to record and report any identified discrepancies.
Perform a regular compliance review
The compliance review allows a firm to look back to make sure that the firm’s policies and procedures are working as intended, and gives the MLRO the opportunity to identify gaps in staff knowledge or money laundering risks, policies and procedures that the firm can deal with through tailored training.
Firm-wide risk assessments
The risk-based approach underpins the MLR17 – firms should focus their resources on the services and clients that have the highest risk of money laundering. To determine how and where resources should be focused, firms must perform a risk assessment to understand the risk that the firm may be used to conceal or launder the proceeds of a crime.
Anti-money laundering supervision report
Read the 2024/25 AML Supervision Report to find out about the supervisory activity undertaken by the quality assurance team.
