AML Compliance Advisory

Yes, in certain circumstances an AML fine can be reduced or appealed, but only when clear grounds exist. Regulators usually consider the level of cooperation from the firm, whether remedial action was taken promptly and if senior management understood and addressed the risks. Even if a reduction is not possible, how you respond is highly important. Implementing a robust remediation framework can significantly lower the risk of further enforcement action, additional fines, or increased regulatory scrutiny. We regularly assist firms with post-enforcement remediation and engagement with regulators.

It’s not always required, but it’s usually a very smart move. Bringing in an independent reviewer shows you’re serious about fixing things, adds credibility with the regulator, and proves you’re approaching the situation objectively. In fact, many regulators expect firms to seek outside AML expertise after enforcement action. We offer independent AML compliance reviews that are practical, proportionate, and ready to meet regulatory expectations.

An AML compliance review is a thorough mock audit of your firm’s anti-money laundering framework, carried out before your supervisory authority conducts its own examination. We assess your AML policies, firm-wide risk assessment, customer due diligence processes, training records, and overall risk management approach to ensure alignment with current Money Laundering Regulations. You should consider a review if you have never had independent compliance verification, have received regulatory correspondence, your business has changed since the last review, you are approaching an AML inspection, or you want to proactively prepare for eventual FCA supervision. Our reviews pinpoint gaps and deliver practical remediation plans, complete with ready-to-use documentation.

Following an AML compliance review, we create a documented remediation plan, reporting the issues we identified. This will help you pinpoint where the issues are and implement yourself. We can even help you with a plan to do that.

If you choose to use our expertise, our service includes updating your AML policies, Firm-Wide Risk Assessment and staff training to demonstrate your commitment to compliance. Our approach is prescriptive rather than suggestive; we tell you exactly what you must do to meet regulatory obligations We typically deliver emergency reviews within 5-7 working days and provide ongoing support to prevent future penalties. Contact us immediately as early intervention significantly improves outcomes with your AML supervisor.

Yes. While many cases result in civil penalties, serious or repeated failures can expose firms and individuals to: Criminal investigation Personal liability for MLROs or senior managers Restrictions on future regulatory permissions. Effective AML frameworks protect not just the firm, but the people running it.

No, small firms aren’t expected to have the same controls as large organisations but they do need controls that fit their specific risks. Regulators look for a risk-based approach, proportionate documentation, and clear accountability. Small firms often get fined not because of their size, but because their AML arrangements are copied from elsewhere, too generic, or not fully understood. We focus on building AML frameworks that are the right fit for your business. Nothing over-engineered, just what you need.

Both. We provide flexible engagement models including: one-off compliance reviews and remediation projects, annual retainer agreements for ongoing advisory support, quarterly performance tracking and compliance health checks, and ad-hoc consultation for specific transactions or queries.

Our retainer clients receive priority response times (typically under 48 hours). This is ideal for firms wanting continuous expert support without hiring a dedicated compliance officer.

Our retainer clients receive responses within 48 hours as standard, often within 24 hours for urgent matters. Emergency compliance reviews following AML penalties are typically scoped within 48 hours with delivery within 5-7 working days. We understand AML issues are often time-sensitive services.