Project managing your AML work

‍Why structure matters

As client complexity increases and regulations evolve, firms need more than one-off checklists. A structured approach helps your team:

• Comply with MLR 2017, POCA, and supervisory guidance
  
• Spot and fix issues before they become risks
  
• Handle audits or red flags with confidence
  
• Scale AML processes as your firm grows
  

Without a clear system, compliance gaps and inefficiencies can quickly build up.

How to keep AML work under control (without overcomplicating it)

1. Build a strong foundation

• Keep your AML policies and procedures clearly documented and centralised
  
• Ensure they reflect how your team actually operates
  
• Review and update at least annually, or when there’s a regulatory or business change
  

2. Standardise onboarding and risk checks

• Use digital ID verification tools with a reliable audit trail
  
• Implement a checklist to confirm PSCs, risk levels, and verification steps
  
• Set automated reminders for periodic reviews based on client risk
  

3. Deliver focused staff training

• Schedule short AML refreshers at least twice a year
  
• Cover red flag awareness and clear escalation steps
  
• Track completion and follow up with relevant staff
  

4. Maintain secure, consistent record keeping

• Store ID checks, risk assessments, SARs, and policies in one accessible, secure system
  
• Apply permission levels to control access to sensitive information
  
• Use reminders for when reviews or deletions are due under MLR and GDPR
  

5. Monitor, review, and improve

• Schedule a brief AML compliance review every quarter
  
• Track issues and improvements in one shared location (e.g. spreadsheet or dashboard)
  
• When a risk, error, or change is identified, reflect it in your process — not just your inbox
  

Summary

AML compliance can be complex, but your internal processes don’t need to be.

Focus on a few key areas:

• Documented policies and procedures
  
• Consistent onboarding and verification
  
• Targeted staff training
  
• Secure record keeping
  
• Regular internal reviews
  
  

Managing AML like a structured process helps your firm stay compliant, confident, and prepared for change.

This article was summarised by the Firmcheck content team. The original content was written by independent AML expert Ian Waters and is available on our blog.

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