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Anti-money laundering

Review of policies, controls and procedures

This page is part of a series on the 10 most common issues we've found when reviewing firms' compliance with the Anti-money Laundering Regulations.
See the 10 most common issues
You should plan to regularly review the effectiveness of your AML policies and procedures It doesn’t need to be an external review but you should design this to be as independent as possible, given the size and nature of your firm.

What do the regulations say?

The regulations say that firms must establish an independent audit function to assess the adequacy and effectiveness of the firm’s AML policies, controls and procedures. Sole practitioners with no employees are exempt from this requirement.

Where the firm identifies any gaps or weaknesses during a review, it should document how it intends to address them.

Why is it important?

It enables your firm to assess the level of compliance with the Money Laundering Regulations and to ensure your anti-money laundering policies and procedures are effective. 

Where failures are not identified you risk breaching money laundering regulations and/or facilitating money laundering. 

What we found in our 2021/22 AML compliance reviews

Some of the firms we reviewed hadn't performed a regular review of the adequacy and effectiveness of their policies, controls and procedures.

Resources to support compliance

Read the report

Read our 2021/22 anti-money laundering supervision report for more detail on the results of our monitoring reviews, the outcomes of those reviews and enforcement action taken. The report also summarises all of our anti-money laundering supervisory activity during the period.