Independent Internal AML Audit
A proactive internal AML audit is essential for Authorised Electronic Money Institutions (AEMIs) to ensure their anti-money laundering and counter-terrorist financing (AML/CFT) controls are effective, operational, and fully compliant with FCA regulations, MLR 2017, and FATF guidance. ABM Global provides an in-depth, independent assessment of your AML framework, offering actionable insights to strengthen compliance and prepare for external regulatory inspections.
Comprehensive AML Framework Review
We evaluate your AML policies, procedures, and operational controls to ensure alignment with regulatory requirements and best practices. This includes assessing customer due diligence (CDD) processes, enhanced due diligence (EDD) for high-risk clients and politically exposed persons (PEPs), and transaction monitoring protocols. Our review ensures your AML framework is complete, coherent, and effectively integrated into daily operations.
Transaction Monitoring & Escalation Assessment
ABM tests the real-world functionality of your transaction monitoring systems, including alert thresholds, automated monitoring tools, and manual review processes. We examine escalation protocols to ensure suspicious activities are identified promptly, properly investigated, and reported in accordance with regulatory timelines.
Reporting Channels & SAR Compliance
Our audit verifies that reporting channels for suspicious activity are clear, functional, and compliant. We review the adequacy of Suspicious Activity Report (SAR) procedures, including documentation, submission processes, and audit trails, ensuring readiness for FCA scrutiny.
Staff Competency & Training Review
We assess the effectiveness of AML training programs for staff, management, and the MLRO. This includes evaluating the sufficiency of role-specific training, awareness of AML/CFT responsibilities, and understanding of escalation procedures, helping to cultivate a proactive compliance culture.
Control Testing & Risk Assessment
ABM conducts practical testing of key AML controls to identify operational gaps, weaknesses, or inefficiencies. We assess whether high-risk clients, transactions, and products are effectively monitored, and whether remediation actions are implemented promptly.
Gap Analysis & Recommendations
Our team provides a detailed evaluation of deficiencies and actionable recommendations to strengthen controls, improve risk mitigation, and enhance the overall AML framework. Recommendations cover policy enhancements, procedural improvements, and staff awareness measures.
Regulatory Inspection Preparedness
ABM supports preparation for FCA inspections, including mock audits, documentation review, and advisory sessions for staff and MLROs. This ensures your AEMI can demonstrate a robust, effective, and proactive AML compliance program, instilling confidence in regulators and stakeholders.


