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AML Gap Analysis: A Practical Checklist for Finding Control 

Practical Checklist for Finding Control Weaknesses


When did you last check whether your AML procedures are being followed?

A customer file may look complete until you check the ownership details. A screening alert may be closed without a clear explanation. These are the kinds of gaps this guide helps you find.

Work through nine areas of your AML programme, examine the records behind decisions and note what needs fixing. The guide also includes a findings register format for assigning actions and following up.

What You’ll Learn in This Checklist?

Find Gaps in Everyday Work

Compare your procedures with what happens during onboarding, reviews and approvals.

Take a Closer Look at Customer Files

Check whether identity records, ownership details and risk ratings support the decisions made.

Follow Alerts Through to a Decision

See what your team checked, why an alert was closed and whether concerns were escalated.

Decide What to Fix First

Record each issue, assign someone to address it and agree on how completion will be checked.


What’s Inside the Guide?

Compare your procedures with daily work to find missed checks and unclear responsibilities.

Examine ownership details, risk ratings and the reasons behind screening and monitoring decisions.

Prioritise findings, assign owners and set deadlines for corrective actions.

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