Client AML work is not difficult. Keeping it in a state you can produce on demand is where practices come unstuck, usually because the material is scattered.
The four parts of a client file
- Identity verification — who the client is, checked and held
- Risk assessment — your judgement about that client, recorded
- Ongoing review — that judgement revisited rather than frozen at onboarding
- Audit trail — dated evidence that the other three happened
A file missing any one of these is thin, even where the underlying work was done properly.
Keep it against the client, not in a folder
The single biggest improvement most practices can make is location. When AML material sits on the same client record as everything else, it does not drift, and it does not have to be found.
Schedule the review
Onboarding assessments age. Where review is scheduled against the client, the file stays current without depending on anyone remembering the anniversary.
Control who sees it
AML material should follow role-based access — visible to the people whose job requires it rather than to everybody with a login.
The inspection test
Ask yourself how long it would take to produce the complete AML position for one client, picked at random. If the answer is more than a minute, the material is in the wrong place.