AML Audit

Regulation 21 of the Money Laundering Regulations 2017 requires many regulated businesses to establish an independent audit function: someone with no role in designing or operating the firm's AML controls must examine whether they are adequate and actually followed. Supervisors — HMRC, the FCA, the SRA and the professional bodies — now routinely ask for evidence of that audit, and 'we review ourselves' is not an answer that survives a visit.

Acumon provides that independent examination: we test your firm-wide risk assessment, your customer due diligence in practice rather than on paper, your monitoring and reporting arrangements, and we report findings you can hand to your supervisor with confidence.

Who Needs an Independent AML Audit

The requirement applies to businesses within the Money Laundering Regulations where the size and nature of the business make it appropriate — in practice, most firms of any substance in the regulated sector: accountancy and legal practices, estate and letting agents, high-value dealers, art market participants, trust and company service providers, and cryptoasset businesses. If your supervisor has asked whether you have an independent audit function and the honest answer is no, that is the gap this service closes.

What the Audit Examines

We test the full chain the regulations require: the firm-wide risk assessment and whether it reflects your actual client base; policies, controls and procedures and whether staff follow them; customer due diligence files — including enhanced due diligence for higher-risk clients and source-of-funds work; ongoing monitoring; suspicious activity reporting arrangements; training records; and record-keeping. The consistent finding across the sector is a gap between documented procedures and daily practice — which is exactly what independent testing exists to find.

File Testing, Not Policy Reading

An AML audit that only reads your manual is worthless. Ours samples real client files and walks each through the requirements: was the risk rating justified, was identity verified before the engagement, was EDD triggered and performed, would this file satisfy an inspector? Findings come back specific — which files, which gaps, which fixes — so remediation is a task list rather than a philosophy.

Reporting Your Supervisor Will Recognise

The output is a clear written report: scope, methodology, findings graded by severity, and practical recommendations with owners and timescales. It is written knowing a supervisor may read it — demonstrating that the audit was genuinely independent, appropriately skilled and acted upon is precisely what Regulation 21 compliance looks like from the outside. A follow-up review confirming remediation closes the loop.

Independence by Design

Because Acumon is an ICAEW-registered and FRC-regulated audit firm, independence is not a claim but a discipline we are inspected on. We take no role in operating your AML controls, which is what makes the audit valid — and if you also need help fixing what we find, we will tell you plainly where the line sits between auditing your framework and building it.

What You Get With Acumon

• Independent AML audit satisfying Regulation 21 of the MLRs
• Firm-wide risk assessment reviewed against your actual client base
• Real client file sampling: CDD, EDD, source of funds and monitoring
• SAR arrangements, training and record-keeping tested
• Findings graded by severity with owners and timescales
• A report written to withstand supervisor scrutiny
• Follow-up remediation review to close the loop
• Delivered by an ICAEW-registered, FRC-regulated audit firm

Why Acumon for AML Audit?

• ICAEW-registered and FRC-regulated — independence is an inspected discipline, not a claim
• Team of 70 audit professionals, more than half from leading international accounting firms
• Acumon operates under the Money Laundering Regulations itself and is supervised for AML — the regime is home ground
• Anti-fraud and forensic capability in-house for matters that escalate

Get a Fixed-Fee Quote

Tell us what you need and we'll come back within one business day with a clear scope and a fixed price — no hourly-rate surprises. Call 020 8567 3451 or use the form and we'll be in touch.