AML Consulting and Advisory
AML consulting connects an organisation's money laundering risks with the policies, controls and daily processes used to manage them. Trevor Barritt's advice starts with the business question, available evidence and relevant jurisdictions.
AML advice for your business
AML advice can help when an organisation needs to connect its risk assessment with procedures and oversight, evidence a control, or adapt its programme to changes in products or customers. The work starts from the firm's specific business question and operating model.
An initial conversation identifies the relevant entity and activities, jurisdictions, decision, available documents and systems, and accountable people. If an advisory engagement is appropriate, its evidence base, boundaries and any written or workshop output are agreed before work begins.
Connect risk to controls and operating decisions
An AML review examines how a firm's risk profile informs policies and procedures; how customer, product, activity and distribution risks shape controls; and how ownership, information and processes fit together. It can also trace how new products, customers or changes in the business enter the control environment and how issues are recorded, escalated and reviewed.
For UK firms to which the relevant provisions apply, FCA Handbook SYSC 6.3 addresses identifying, assessing, monitoring and managing money laundering risk, with systems and controls proportionate to the nature, scale and complexity of a firm's activities. The exact rules that apply depend on the firm. FATF Recommendations set international standards for countries to implement through measures adapted to their circumstances; they are not a substitute for checking applicable national requirements.
Clarify the decision and the boundary
The work can focus on a defined issue, population and period. Depending on the question, it may involve policy analysis, process mapping, selected evidence or interviews with relevant stakeholders. Findings make assumptions and information gaps clear, and inform decisions that remain with the firm's governing body and accountable officers.
International enquiries are welcome. Trevor Barritt's UK financial services and regulatory experience can inform the work, while local law, supervision, business model and available evidence shape recommendations in each jurisdiction.
Related advisory questions
Governance and controls questions focus on accountability, policies and operational practice. Transaction monitoring advice addresses scenarios, data, alerts and investigations; technology advisory addresses systems, supplier decisions and AI oversight. Separate advice can cover customer due diligence, beneficial ownership, MLRO responsibilities, sanctions or training.
Common questions
What should I bring to an initial AML consulting discussion?
A concise description of the business concern, the relevant entity and jurisdictions, what decision is needed, what has already been examined, and the types of documents or systems involved is useful. Avoid sending identifiable customer information until a suitable process has been agreed.
Does AML consulting include a formal audit or regulatory assurance?
Not by default. The parties agree the review question, evidence sample, assurance level and output before work begins. Advice does not replace a firm's regulatory responsibilities or guarantee compliance.
Can the discussion cover more than one jurisdiction?
International enquiries are welcome. The relevant jurisdictions and rules need to be identified and agreed for each engagement; an international standard alone does not establish local legal requirements.