What is an independent internal AML audit?

An independent internal AML audit is a review carried out by an external or internally independent team that evaluates how well your organisation’s AML/CTF framework is designed and operating, identifies gaps, and offers recommendations for improvement.

Why is it important to test operating effectiveness of AML controls?

Testing operating effectiveness ensures that controls are not only documented but are actually working in practice, reducing risk of non-compliance, financial crime, or regulatory penalties.

How do you identify gaps in AML compliance during an audit?

Gaps are identified by comparing existing processes, policies and controls against regulatory requirements and best practices, reviewing documentation, sampling transactions, interviewing staff, and analyzing system logs or metrics.

What is involved in recommending remediation plans?

A remediation plan outlines specific corrective actions, assigns responsibilities, sets timelines, prioritises high risk issues, and monitors implementation to ensure improvements are effective.

Is follow-up verification part of the service?

Yes. Follow-up verification confirms that remediation steps were properly implemented and that AML controls are now operating as intended.

Who should receive the audit report?

The audit report should typically be delivered to senior management, the board of directors, compliance or risk committees, as well as other internal stakeholders responsible for oversight and regulatory compliance.

How often should independent internal AML audits be conducted?

Frequency depends on factors such as size of the organisation, risk profile, regulatory requirements, any prior issues or changes in operations; often annually or bi-annually.

Does ABM Global Compliance assist in implementing corrective actions from audit findings?

Yes, part of the service includes helping you put in place corrective measures, updating policies and procedures, training staff, and verifying that the improvements are functioning properly.

Independent Internal AML Audit | Internal Audit for SPI/MSB

Independent Internal AML Audit

For Small Payment Institutions (SPIs), an independent, internal review of the AML/CFT program is a critical pillar of a robust compliance framework. Regulators such as the FCA and HMRC expect firms to regularly assess the effectiveness of their controls, proactively identify gaps, and demonstrate a strong culture of risk management.

At ABM Global, our Independent Internal AML Audit delivers a thorough, objective, and practical assessment of your AML controls. The audit not only ensures regulatory readiness but also strengthens operational resilience, safeguards against financial crime, and reinforces investor and stakeholder confidence.

ABM’s Independent Internal AML Audit Includes

1. Comprehensive AML Framework Assessment

In-depth review of AML/CFT policies, operational procedures, and internal controls to ensure they are fit for purpose.
Evaluation of alignment with FCA Handbook requirements, MLR 2017 guidance, and FATF Recommendations.
Assessment of program consistency and robustness across all operational units, business lines, and geographies.
Verification that policies and procedures are practical, actionable, and embedded in day-to-day operations.

2. Control Effectiveness Testing

Validation that key AML controls—including Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), transaction monitoring, and SAR processes—function as intended.
Testing of alert handling, escalation pathways, and remedial action procedures to confirm timely and effective intervention.
Identification of control gaps, process inefficiencies, and compliance weaknesses, with emphasis on practical improvement measures.

3. Risk-Based Review

Detailed analysis of high-risk clients, complex products, and high-risk jurisdictions to ensure enhanced controls are applied appropriately.
Assessment of ongoing monitoring processes, periodic risk reviews, and risk scoring mechanisms to maintain a dynamic, responsive AML program.
Guidance on mitigating emerging risks, including typologies for fraud, money laundering, and terrorist financing.

4. Regulatory Inspection Preparedness

Preparation for FCA, HMRC, or internal audits, including compilation of evidence, control documentation, and workflow records.
Conducting mock inspections and readiness assessments to identify potential scrutiny points before regulators visit.
Advisory support for MLROs, compliance officers, and operational staff on presenting AML processes, findings, and results effectively during inspections.

5. Gap Analysis & Recommendations

Objective identification of policy, control, or procedural deficiencies within the AML/CFT framework.
Delivery of prioritized, actionable recommendations to strengthen controls, improve risk mitigation, and enhance operational efficiency.
Support in implementation of remediation plans, ensuring sustainable improvements and long-term regulatory compliance.

6. Continuous Monitoring & Follow-Up

Ongoing advisory support to maintain and enhance AML control effectiveness after the audit.
Assistance in tracking improvements, updating policies, refining monitoring systems, and reporting mechanisms.
Ensuring your AML program adapts to regulatory changes, emerging risks, and business growth, maintaining continuous compliance and operational integrity.