Regulators no longer assess whether firms have AML/CFT policies. They assess whether those policies are effective, implemented, and proportionate to risk.
An independent AML/CFT audit goes beyond surface-level checks. It provides an objective assessment of how well a firm’s framework operates in practice, including whether controls genuinely mitigate identified ML/TF risks.
A robust AML/CFT audit assesses the design, implementation, and operating effectiveness of a firm’s AML/CFT framework across key risk areas, including:
• AML/CFT policies, procedures, and internal controls
• Compliance with FIAMLA, the FIAML Regulations 2018, and the FSC AML/CFT Handbook
• Internal AML/CFT risk assessment and third-party risk oversight
• Effectiveness of the Compliance Officer and MLRO functions
• Mitigating controls, including CDD, enhanced measures, and sanctions screening
• Suspicious transaction monitoring, escalation, and reporting processes
• AML/CFT training, record-keeping, and documentation standards
Critically, regulators also look at how firms respond to audit findings – whether issues are remediated promptly and controls strengthened over time.
At Acrion, our independent AML/CFT audits are designed to bridge the gap between regulatory expectations and operational reality. We provide clear, prioritised, and practical recommendations that firms can implement without disrupting business continuity.
An independent audit done properly is not a tick-box exercise. It is an opportunity to strengthen governance, reduce regulatory exposure, and demonstrate a proactive compliance culture.
As an independent compliance specialist, Acrion delivers objective, credible AML/CFT audits that regulators trust and firms can rely on.
Navigating Compliance. Managing Risk. Differently
