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The next instalment from Firmchecks AML Essential Kit covers policies, controls and procedures.
AML policies, controls and procedures are the backbone of your compliance framework. Together, they define how your firm understands and manages the risks of money laundering and terrorist financing.
Policies outline your firm's AML commitments and responsibilities.
Controls reduce risk and ensure consistency.
Procedures provide step-by-step instructions so staff know exactly what to do.
To stay compliant, your documents must be tailored to your firm’s services, clients, and structure — and kept up to date as things change. A clear framework helps protect your firm, support your team, and demonstrate a serious approach to compliance.
Every UK accounting firm is legally required to have AML policies, controls and procedures in place. These three components form the framework for how your firm manages its AML responsibilities in practice. - Policies define your firm’s commitment to compliance and outline its principles and expectations - Controls are the safeguards used to reduce AML risks and enforce those policies - Procedures are step-by-step instructions that staff follow to carry out their AML responsibilities Together, they show how your firm understands AML risk and how it plans to stay compliant.
Strong AML policies, controls and procedures are a legal requirement under regulation 19 of the Money Laundering Regulations (MLR 2017). But beyond compliance, they also:
Help your team know what’s expected of them
Reduce the risk of mistakes or oversight
Provide evidence of compliance in case of a regulatory inspection
Create consistency across the firm, even as teams grow or change
Supervisors frequently cite weak or generic AML documentation as a cause of non-compliance. Your framework must be tailored to your firm’s size, services, client base and risk exposure.
The AML Essential Kit will guide you through how to build your AML policy, controls and procedures framework:
AML Policies - Purpose & scope, relevant legislation, roles & responsibilities, risk management, monitoring & reporting, record keeping and internal controls and training
AML Risk
AML Controls - Senior Management oversight, screening and training & independent review
AML Procedures - Client onboarding & due diligence, record keeping, suspicious activity reporting, employee training
AML policies, controls and procedures form the foundation of your compliance framework. They show regulators — and your team — how seriously your firm takes its AML obligations.
To stay compliant:
Define clear, tailored AML policies based on your risks and services
Put controls in place to monitor, review and improve your AML processes
Create step-by-step procedures so staff know exactly what to do
Regularly review and update your documentation to reflect changes in law, risk, or your firm’s operations
By combining all three elements — policies, controls and procedures — you build a robust, risk-based approach to AML compliance and a clear roadmap for your team to follow.
View all the details and the full AML Essential Kit here - https://www.firmcheck.com/aml-essential-kit/firm-policies-controls-and-procedures
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