A structured start-of-year compliance checklist helps ensure key obligations are not overlooked:
✔️Business Risk Assessment updated
Your enterprise-wide ML/TF risk assessment should reflect current business activities, client composition, product exposure, delivery channels and geographic risk.
✔️Ongoing File Review calendar set
Higher-risk relationships require scheduled and properly documented file reviews. A structured review calendar demonstrates consistency, traceability and regulatory discipline, while helping ensure ongoing monitoring obligations are met in practice – not only in policy.
✔️Policies and Procedures updated
Policies must reflect current laws, regulatory guidance and operational realities. Outdated documents are often the first red flag in inspections.
✔️Client CDD documents reviewed
Ensure identification, verification and supporting documentation remain valid, complete and aligned with risk classification.
✔️Client Risk Assessments reviewed
Client risk scoring should be dynamic – changes in activity, ownership, geography or behaviour must trigger reassessment.
✔️Mandatory training completed
Board members, Compliance Officers, MLROs and staff should complete annual AML/CFT training, with attendance properly recorded and retained.
✔️Written Declaration of Beneficial Owners submitted
Following the introduction of the requirement last year, firms must ensure the written declaration of beneficial owners is completed and submitted by 30/06/2026. Institutions should verify accuracy, ensure alignment with internal registers and maintain proper supporting documentation ahead of the deadline.
Regulatory expectations continue to intensify. Firms that begin the year organised, documented and proactive are better positioned for onsite inspections, thematic reviews and supervisory engagement.
Acrion supports institutions with Business Risk Assessments, compliance framework reviews and practical readiness support tailored to evolving regulatory standards.
Navigating Compliance. Managing Risk. Differently
