AML Systems and Controls Review

Connect risk to control operation

The review starts with the firm's activities, products, customers and relevant jurisdictions. It considers how the business-wide risk assessment informs policies and procedures, customer risk decisions, monitoring, escalation and oversight. The aim is to identify where the control framework reflects the actual exposure of the business, and where assumptions or gaps need closer examination.

Depending on the agreed scope, attention may fall on customer due diligence, transaction monitoring, sanctions screening, suspicious activity escalation, training, record keeping, or the hand-offs between these activities. This is a focused review of design and operation; it is not a substitute for a firm's own risk assessment, legal advice or statutory audit.

Evidence, ownership and testing

A useful assessment looks beyond whether a policy exists. It asks whether named roles understand their responsibilities, procedures are usable, management information supports challenge, and controls are tested at a level suited to the risk. Depending on the question and available access, this can include walkthroughs, review of control records and a proportionate sample of cases or alerts. Sampling can reveal how a process operates, but does not by itself establish that every case is effective.

Relevant inputs may include the business-wide and customer risk assessments, policies, procedures, committee papers, management information, testing results, exception logs and selected case records. The scope and handling of sensitive information are agreed before review. Conclusions should distinguish what the evidence demonstrates from what remains uncertain or needs further testing.

• Control purpose, accountable owner and escalation route
• Alignment between assessed risks, policy requirements and operational steps
• Testing approach, sample rationale, exceptions and evidence quality
• Whether management information enables meaningful review and challenge

Findings that support decisions

The review distinguishes design weaknesses from execution issues, evidence gaps and matters that need specialist legal or regulatory input. Findings link each issue to the supporting records and identify further evidence or decisions that could help address it.

This controls review centres on whether arrangements are designed and operating as intended. A separate AML risk assessment focuses on identifying and evaluating the firm's exposure. AML governance work centres on senior oversight, accountability, challenge and decision-making. Where review identifies deficiencies, remediation work concerns the actions, owners, sequencing and follow-through needed to address them. Keeping those questions distinct helps avoid treating a governance discussion or action plan as evidence that the underlying control has been tested.