Selected for an AML inspection? Here are some key things to be aware of

Carl-Fredrik Hedengren

Written by Carl-Fredrik Hedengren, Founder at AML Audit & Advisory AB (AML-Portalen.se)
Publishing date: 18 February 2025

If your company has been selected for an inspection, thorough preparation is essential. Regulatory authorities frequently assess businesses to ensure compliance with anti-money laundering (AML) regulations. As these regulations are complex and continually updated with new guidance from authorities, it is crucial to stay informed about the latest developments.

One of the most significant risks businesses face is underestimating their exposure to money laundering activities. Industries such as auditing and accounting are particularly vulnerable, as criminals employ sophisticated methods to falsify documents and conceal illicit transactions. Authorities are continuously tightening compliance expectations, emphasising the need for businesses to conduct thorough risk assessments and implement robust risk management strategies.

To help you prepare, we have identified key areas that businesses should focus on in anticipation of a potential inspection.

Keeping Up with Regulatory Developments

A key challenge is staying up to date with regulatory changes, particularly the authorities’ evolving expectations and interpretations of how regulations should be applied. Many supervisory authorities expect companies to promptly integrate new regulatory guidance into their internal policies. This means businesses must actively monitor updates from regulatory bodies and ensure that their risk assessments and compliance procedures remain current.

To ensure your firm remains proactive, it is important to dedicate time and resources to monitoring industry and regulatory developments. This could include subscribing to updates from regulatory bodies, industry associations, or sector experts to stay informed about any changes in compliance requirements.

Conducting Comprehensive Risk Assessments

Risk assessments, a fundamental component of compliance, must be tailored to a company’s specific operations and customer base. Common issues include:

  • Failing to justify risk levels assigned to services or clients.
  • Overlooking geographical risk factors.
  • Not clearly linking identified risks to appropriate mitigation strategies.

Supervisory authorities are highly thorough and, in some cases, have required companies to provide detailed risk descriptions—even when a particular risk is not relevant to the business at the time of inspection. Therefore, a comprehensive and well-documented risk assessment is crucial for demonstrating regulatory compliance and should be updated regularly.

To strengthen your firm’s risk management, it is advisable to establish a standardised risk assessment framework that evaluates customers, services, and geographical exposure. Additionally, a structured process should be in place to review and update risk assessments at least annually.

Strengthening Policies and Procedures

Another key focus during inspections is the effectiveness of policies and procedures. Many businesses fall short in areas such as Customer Due Diligence (CDD). It is essential that company policies contain clear, up-to-date guidelines on compliance requirements, supported by structured training programmes to reinforce best practices.

Regular internal compliance checks help businesses identify and address deficiencies before they are flagged during an inspection. It is therefore advisable to implement a system for periodic reviews of policies and processes, ensuring that compliance procedures remain effective and up to date.

Additionally, ongoing staff training is vital, ensuring that employees understand the correct procedures and are aware of key compliance risks in their daily work.

Ensuring Robust Data Management and Documentation

Supervisory authorities also pay close attention to how businesses manage data and documentation. Poor record-keeping, inadequate tracking of customer identity verification, and a lack of structured oversight in business relationships can all raise red flags.

Businesses must ensure that all compliance-related actions—including identity checks, risk assessments, and monitoring processes—are properly documented to demonstrate compliance in the event of regulatory scrutiny.

By maintaining an organised and secure system for data management and compliance documentation, businesses can easily retrieve necessary records if selected for an inspection.

Conclusion

Regulatory inspections are becoming increasingly rigorous, and failure to prepare adequately can result in financial penalties and damage to a company’s reputation. However, by proactively updating risk assessments, strengthening policies, providing ongoing staff training, and maintaining detailed compliance records, businesses can confidently navigate inspections.

Staying ahead of regulatory expectations is not just about avoiding sanctions—it is also about safeguarding the integrity and resilience of your organisation. Preparing now ensures that, when an inspection occurs, your company is in a strong position to demonstrate compliance and operational transparency.

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