AML Compliance


An FCA regulated firm must establish, implement and maintain adequate policies and procedures sufficient to ensure compliance of the firm including its managers, employees and appointed representatives (or where applicable, tied agents) with the firm's obligations for countering the risk that the firm might be used to further financial crime.

A firm must ensure policies and procedures include systems and controls that: (1) enable it to identify, assess, monitor and manage money laundering risk; and (2) are comprehensive and proportionate to the nature, scale and complexity of its activities.


Compliance risk

Example risks, include:

  1. Compliance activity does not inform senior management on the effectiveness, or otherwise, of financial crime systems and controls
  2. Inadequate scoping or implementation of review activity when testing financial crime systems and controls
  3. Blinkered compliance focusing on minimum regulatory standards, or assurance personnel lacking financial crime experience

Effective arrangements

Arrangements which demonstrate senior management engagement in managing financial crime risk:


How we can help you

FCRM provides advisory services to assist client planning and scoping of AML compliance reviews; with clarity of scope, remit and deliverables.

We provide specialist technical resource to complement and support clients' AML capability in Compliance and Internal Audit functions.

We conduct independent reviews of client AML arrangements, including activity undertaken by out-source service providers (e.g. customer service centres and transaction/payment processors).



Integrity in Business Practice