Independent Internal AML Audit

Regular internal review of anti-money laundering (AML) and counter-terrorist financing (CFT) controls is a fundamental component of a strong compliance framework for Authorised Payment Institutions. Regulators, including the FCA, expect firms to demonstrate proactive oversight, assess the effectiveness of implemented controls, and address potential gaps before they escalate into regulatory concerns. ABM Global’s Independent Internal AML Audit provides a thorough, objective assessment of your AML/CFT program, helping your API maintain compliance readiness, operational integrity, and financial crime risk mitigation.

Comprehensive AML Framework Assessment

Our audit begins with a detailed review of your AML policies, procedures, and internal controls. We evaluate alignment with FCA Handbook requirements, MLR 2017, and FATF recommendations, ensuring that your AML program is consistent, well-documented, and operationally effective across all business units.

Control Effectiveness Testing

ABM tests the functionality of key AML controls, including customer due diligence (CDD), enhanced due diligence (EDD), transaction monitoring, and suspicious activity reporting (SAR). We examine alert handling, escalation procedures, and remedial actions to verify that controls operate as intended and identify any gaps or process inefficiencies.

Risk-Based Review

Our team assesses high-risk clients, products, and jurisdictions, ensuring that enhanced controls are appropriately applied. We review ongoing monitoring, periodic risk reviews, and client risk scoring to confirm that your AML program remains dynamic and responsive to emerging threats.

Regulatory Inspection Preparedness

We support preparation for FCA inspections, HMRC audits, or internal reviews by reviewing documentation, conducting mock audits, and compiling evidence of effective controls. Guidance is provided for MLROs and staff on presenting AML processes and outcomes clearly to regulators, demonstrating proactive compliance and operational accountability.

Gap Analysis and Recommendations

ABM identifies control deficiencies, procedural gaps, and compliance weaknesses, providing actionable, prioritized recommendations to strengthen AML controls, enhance operational efficiency, and improve regulatory readiness. We also support the development and implementation of remediation plans to address identified issues effectively.

Continuous Monitoring and Follow-Up

Our services extend beyond the audit itself, providing ongoing advice to maintain AML control effectiveness. This includes tracking improvements, updating policies, refining monitoring systems, and ensuring that your API maintains a robust, regulator-ready AML/CFT program capable of adapting to evolving risks and regulatory expectations.