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Independent AML audit

An independent test of whether your anti-money laundering framework works in practice.

Reviewed by Harry Khan, Founder · 10 November 2026

An independent AML audit examines whether a firm’s anti-money laundering policies, controls and procedures are adequate and are working, and recommends what to fix. The Money Laundering Regulations 2017 require firms to have an independent audit function where appropriate to their size and nature.

What we test

We test your framework against the Money Laundering Regulations, the FCA’s expectations and your own policies.

  • The business-wide risk assessment and how it drives your controls
  • Customer due diligence, enhanced due diligence and ongoing monitoring, on a sample of real files
  • Transaction monitoring rules, alert handling and investigation records
  • Sanctions screening at onboarding and in payment flows
  • Suspicious activity reporting and the MLRO’s decisions
  • Training, governance and the MLRO annual report

See also: Financial crime services · Outsourced MLRO

How the audit runs

  1. PlanWe agree scope, sample sizes and the period tested with your MLRO.
  2. TestWe review documents, test samples of customer files and alerts, and interview the people who run the controls.
  3. ReportYou receive a written report with each finding ranked by severity, the evidence behind it and a recommended action.
  4. Follow upWe can check the actions once they are complete and confirm they work.

What you receive

DeliverableWhat it containsWho relies on it
Audit reportScope, method, findings ranked by severity and recommended actionsBoard, MLRO, FCA
File testing resultsEach sampled customer file and alert, with the result and the gap foundMLRO, operations
Action planEach action with an owner and a target dateBoard, MLRO
Follow-up confirmationEvidence that completed actions workBoard, banks, FCA

Get in touch

Tell us where you are and where you want to be.

[email protected]
+44 7563 115980 (phone and WhatsApp)

Further detail

When firms commission an AML audit

  • Once a year, as part of the firm’s independent audit function
  • Before or after an FCA visit or information request on financial crime
  • When a bank or payment partner asks for independent assurance
  • After a new product, market or customer segment changes the firm’s risk
  • When a new MLRO takes over

What the regulations require

Regulation 21 of the Money Laundering Regulations 2017 requires firms, where appropriate with regard to the size and nature of the business, to establish an independent audit function. That function examines and evaluates the adequacy and effectiveness of the firm’s policies, controls and procedures, makes recommendations and monitors that they are followed.

The FCA has written to payment, e-money and other firms about common weaknesses it finds: risk assessments that do not reflect the business, weak customer due diligence, monitoring that is not tuned to the firm’s customers and slow escalation of suspicion.

Independence

The audit is carried out by people who do not run the controls being tested. Where we already support a firm’s financial crime framework, we say so in the report and keep the audit team separate from that work.

Questions

Is an AML audit a legal requirement?

The Money Laundering Regulations 2017 require an independent audit function where appropriate to the size and nature of the business. For most payment, e-money and crypto firms the FCA expects one, and banks and partners often ask to see the latest report.

How often should we have an AML audit?

Most firms commission one each year, and again after a significant change such as a new product, market or MLRO.

Does the auditor need to be external?

The function must be independent of the people who run the controls. Many firms without an internal audit team use an external adviser to provide it.

What happens if the audit finds problems?

You receive each finding with a recommended action. Most findings are fixed by the firm with an owner and a deadline. Serious failings may need to be reported to the FCA, and we will tell you if a finding falls into that category.

Do you audit crypto and stablecoin firms?

Yes, including blockchain analytics, wallet screening and Travel Rule controls.

Sources

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