What is an AML audit for SEMIs?

An AML audit for SEMIs examines the effectiveness of anti-money laundering and counter-terrorist financing controls, policies, procedures, and reporting, ensuring they meet regulatory requirements and identifying areas for improvement.

How is the transaction and sample testing done?

Transaction and sample testing involves selecting a set of transactions or accounts, validating whether AML controls were applied correctly, checking documentation, and seeing whether any suspicious patterns or errors exist.

What happens in gap analysis?

Gap analysis involves comparing your current AML framework to regulatory requirements or best practices, identifying shortcomings or missing controls, and estimating the risk exposure those gaps create.

What are remediation actions in this context?

Remediation actions are specific, actionable changes to processes, controls, policies or systems designed to address identified deficiencies, improve compliance, and reduce risk.

Is there follow-up verification after the audit?

Yes. To ensure that all recommendations are correctly implemented and controls function as expected, there is a follow-up or validation step.

SEMI AML Audit Services | Regulatory Compliance & Assurance

AML Audit

A strong Anti-Money Laundering (AML) framework is essential for Small Electronic Money Institutions (SEMIs) to operate confidently within FCA regulations. Regulators expect SEMIs to implement robust controls, continuously monitor transactions, and demonstrate the ability to prevent and detect financial crime. ABM provides an in-depth, independent assessment of your AML program, ensuring it meets regulatory standards, mitigates risks, and is inspection-ready.

Policy and Procedure Review

We evaluate your AML/CFT policies and internal controls to ensure they are comprehensive, practical, and fully aligned with the FCA Handbook, Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017), and FATF recommendations. Our review examines whether your policies effectively cover customer due diligence (CDD), enhanced due diligence (EDD) for high-risk clients, politically exposed persons (PEPs), and ongoing transaction monitoring.

Customer Due Diligence (CDD) Assessment

ABM examines your onboarding procedures to confirm that client identification, beneficial ownership checks, and risk classification processes are robust and compliant. We also assess enhanced due diligence measures for high-risk clients, cross-border transactions, and complex ownership structures to ensure that SEMIs operate within regulatory expectations.

Transaction Monitoring and Escalation

We review the design and effectiveness of your transaction monitoring systems, including alert thresholds, pattern detection, and automated monitoring rules. Our audit evaluates how suspicious activities are investigated, escalated, and reported, ensuring timely intervention and compliance with FCA standards.

Suspicious Activity Reporting (SAR) Compliance

Our team ensures that your SAR reporting processes are accurate, timely, and fully documented in accordance with FCA guidance. We also verify that an audit trail exists for all suspicious activity reports, providing evidence of compliance readiness for regulatory inspections.

Gap Analysis and Recommendations

ABM identifies deficiencies, inefficiencies, or risk exposures in your AML framework and provides practical, actionable recommendations to strengthen controls, enhance operational efficiency, and reduce financial crime risk.

Regulatory Inspection Preparedness

We prepare your SEMI for FCA or HMRC reviews by conducting mock inspections, reviewing all AML documentation, and testing operational processes. This ensures your institution can confidently demonstrate that your AML framework is effective and compliant.

Continuous Monitoring and Improvement

Beyond the audit, ABM provides ongoing support to maintain and enhance AML controls, including policy updates, monitoring enhancements, and staff training. This ensures your SEMI adapts to evolving regulatory requirements and emerging financial crime risks.