Five Signs Your AML Programme Needs a Review

AML/CFT frameworks age quickly. Regulations move, your business changes, and controls that were fit for purpose a year ago can quietly fall behind. Here are five warning signs that it may be time for an independent health check before your next regulatory engagement.

1. Your policy hasn’t changed in over a year

If your AML/CFT policy still reflects last year’s products, channels and customer base, it no longer describes how your business actually operates. Regulators expect your documented framework to keep pace with FRC guidance and with changes in your risk profile.

2. Customer due diligence is inconsistent

When different teams collect different information, or high-risk customers slip through with standard checks, your CDD is not doing its job. Gaps in identification, verification and enhanced due diligence for PEPs are among the most common findings in a review.

3. You’ve never tested your controls

Controls that have never been independently tested are assumptions, not assurance. If no one has benchmarked your framework against POCAMLA and global best practice, you don’t yet know where the gaps are.

4. Suspicious transaction reporting is unclear

Staff should know exactly how to escalate a concern and how an STR reaches the FRC through goAML. If that path is undocumented or poorly understood, reports are delayed or missed.

5. Training is out of date

People are your first line of defence. If your board and frontline staff haven’t had recent, role-based training, red flags go unnoticed. A health check tells you which of these gaps matter most and how to close them.