AML and financial crime insights

Start with the decision you need to make

A policy can look complete while its controls fail in operation. A high alert count can reflect risk coverage, poor data or noisy rules. A vendor demonstration can show useful features without proving that a firm can govern the tool or supply the information it needs. These guides focus on the evidence that helps teams tell those cases apart.

The articles are organised around five linked questions. Together they move from control design and monitoring outcomes to technology choices, insurance-specific exposure, and the customer and ownership evidence that supports due diligence. They are intended to help MLROs, compliance leaders, insurance risk teams and AML technology leaders frame a proportionate next step, not to substitute for a firm’s own assessment.

Review whether AML controls work in practice

An AML controls review should connect stated risks to owners, procedures, systems and evidence of operation. The useful test is whether a control addresses a defined risk, whether staff can apply it, and whether exceptions or failures reach someone able to act. The guide helps readers structure that review and separate a missing document from a weakness in the actual control environment.

Assess transaction monitoring performance

Monitoring performance cannot be judged from alert volumes or closure speed alone. Readers are guided to examine the quality and coverage of input data, scenario rationale, alert handling, escalation and feedback from investigations. The aim is to ask whether the system is producing useful, explainable signals for the firm’s risks, and what evidence would support a change to data, rules, workflow or oversight.

Choose AML technology against operating needs

Technology selection starts with the problem, users and operating model, not a feature list. A sound comparison asks what data must be available and how it will be maintained, how decisions and exceptions are recorded, what integration and change support are needed, and where people retain accountability. This guide helps teams test requirements and governance before treating a product demonstration as proof of fit.

Apply an insurance-specific AML lens

Insurance products, distribution, premiums, claims and policy changes can create different risk signals from ordinary account payments. A sector-specific assessment asks where relevant customer, intermediary, beneficiary and transaction information sits, when it becomes available, and how a concern is escalated. The guide draws on dated insurance analysis; readers should check current requirements and the rules for each product and jurisdiction in scope.

Connect KYC, due diligence and ownership evidence

Identity checks establish who a customer says they are; customer due diligence also asks who controls or benefits from an entity and whether the relationship makes sense in context. Registers and documents are evidence to assess, not automatic proof that a complex ownership picture is understood. This guide explains how to relate KYC, CDD and enhanced due diligence, record unresolved discrepancies, and apply jurisdiction-specific thresholds and sources.

Use sources in their proper scope

The FATF Recommendations set international standards for implementation through national measures adapted to local circumstances. UK firms also need to consult applicable FCA rules and guidance; neither an international standard nor a general article determines the obligations for every firm. Source dates are included so readers can check for changes before relying on a point in a live decision.