AML check admin: client due diligence without a backlog

Key takeaways

Under the Money Laundering Regulations 2017, regulated firms such as accountants, conveyancers and estate agents must carry out customer due diligence before taking on clients and keep it current. Collecting documents, running electronic checks, chasing missing items and filing records is repetitive admin. The risk assessment and any reporting decision must stay with your firm.

• Customer due diligence comes before the work starts.
• Collect, check, record, then monitor over time.
• Keep records for 5 years after the relationship ends.
• Risk decisions and suspicious activity reports stay in-house.

What does AML check admin involve?

It involves requesting identity and address evidence, running electronic verification, checking company ownership for business clients, screening for politically exposed persons and sanctions, recording the results and risk rating, chasing missing documents and refreshing checks when circumstances change. HMRC and professional bodies supervise firms for compliance.

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Which steps can a support team run?

A support team can run the collection and checking steps under your firm's written policy, acting as your processor. Your firm remains responsible for compliance and must make the risk judgement. Under the regulations, firms can rely on certain third parties in limited circumstances, but responsibility stays with the firm.

• Request and chase identity documents.
• Run electronic verification and screening.
• Check company ownership and controllers.
• Record results in the client file.
• Flag anything outside policy to the MLRO.

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What does the backlog cost?

In an illustrative example, an accountancy practice onboards 25 clients a month and each check takes about 45 minutes including chasing. That is around 19 hours a month, usually by qualified staff. These are example figures. Work cannot start until checks are complete, so a backlog delays fees as well as using senior time.

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What must stay with your firm?

The firm-wide risk assessment, each client's risk rating, the decision to accept or decline a client, enhanced due diligence decisions and any suspicious activity report must stay with your firm and your money laundering reporting officer (MLRO). Never ask a support team to decide whether something is suspicious.

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What does this look like in practice?

A pattern we see: partners run ID checks themselves because they think nobody else is allowed to. A written policy separating the admin from the judgement lets a team do the chasing while partners make the decisions.

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AML admin checklist

Run the routine with these points.

• Written CDD policy and procedures.
• Standard document request for each client type.
• Checks recorded in the client file.
• Exceptions flagged to the MLRO.
• Refresh dates tracked for ongoing monitoring.

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Next step

Send us your current onboarding steps. We will help you separate the admin from the judgement and say plainly what a support team could run.