What is an AML Audit for an AEMI?

An AML audit reviews an Authorised Electronic Money Institution’s AML/CTF framework — its policies, controls, transaction monitoring, customer due diligence, risk assessments — to check regulatory compliance and operational effectiveness.

What does operational effectiveness testing include?

It includes checking whether documented controls are actually being followed in day-to-day operations — for example, whether transactions are monitored, KYC is performed correctly, and alerts or suspicious activity are escalated appropriately.

What is involved in transaction / sample file review?

It involves selecting sample transactions or customer files and assessing them against your AML policies and regulatory requirements to find any non-conformance, suspicious behaviour or procedural lapses.

How is risk exposure & gap analysis carried out?

By comparing current practices versus regulatory standards and best practices, identifying where there is risk due to missing or weak controls, and quantifying or prioritising these gaps for remediation.

What deliverables are provided after the audit?

Deliverables often include a detailed audit report, identified gaps, risk assessments, recommendations, a remediation roadmap with timelines and responsibilities, and a follow-up to confirm implementation.

AML Audit Services | AEMI Anti-Money Laundering Review

AML Audit

A robust Anti-Money Laundering (AML) framework is essential for Authorised Electronic Money Institutions (AEMIs), due to their larger transaction volumes, cross-border operations, and exposure to complex client relationships. Regulators such as the FCA expect AEMIs to maintain effective AML/CFT controls that can detect, prevent, and mitigate financial crime risks across all business activities. ABM Global provides a detailed and practical AML audit, assessing policies, procedures, and operational effectiveness to ensure full regulatory compliance and operational resilience.

Policy & Procedure Review

ABM examines your AML/CFT policies and procedures in depth, ensuring they are fully aligned with FCA requirements, MLR 2017, and FATF guidance. This includes reviewing customer due diligence (CDD) processes, enhanced due diligence (EDD) for high-risk clients and politically exposed persons (PEPs), onboarding procedures, and transaction monitoring rules. We evaluate whether the policies reflect your operational realities, business model, and the specific risks associated with cross-border payments, electronic money issuance, and diverse client segments.

Transaction Monitoring & Suspicious Activity Reporting (SAR) Processes

Our audit assesses the effectiveness of your transaction monitoring systems, including alert configuration, threshold settings, and automated detection mechanisms. We examine escalation protocols to ensure suspicious activities are investigated promptly and appropriately. SAR processes are reviewed to verify that reporting is accurate, timely, and fully compliant with regulatory obligations, with clear documentation and audit trails to support inspection readiness.

Control Testing & Risk Assessment

ABM performs practical testing of AML controls to determine if they function as intended in day-to-day operations. This includes evaluating high-risk product offerings, client segments, cross-border transactions, and complex ownership structures. We assess whether risk scoring, ongoing monitoring, and periodic reviews are effective in mitigating financial crime risks, and identify areas where controls may be inconsistent or insufficient.

Gap Analysis & Recommendations

We identify weaknesses, inefficiencies, or compliance gaps in your AML framework and provide actionable, prioritized recommendations to strengthen controls. Our guidance includes improvements to policies, procedures, internal controls, and staff awareness, helping your AEMI enhance operational effectiveness while maintaining regulatory compliance.

Regulatory Inspection Preparedness

ABM prepares your institution for FCA inspections or internal audits, conducting mock audits, reviewing documentation, and advising staff on presenting AML controls and processes confidently to regulators. We ensure that evidence of compliance is organized, transparent, and accessible, reducing the risk of regulatory findings and demonstrating a proactive, robust AML culture.