These checklists are designed as a quick reference tool to help you keep your policies and procedures current. They will be particularly useful if you who have had little or no experience so far of what to look for when identifying money laundering.

1. Anti-money laundering To-Do List

2. Anti-money laundering procedures - Annual Review

3. Recognising money laundering - Prompt Sheet


1. AML To-Do list

  1. Appoint an MLRO, unless you are a sole practitioner with no employees, in which case you will be the MLRO by default 
  2. Understand what is meant by Money Laundering and the Proceeds of Crime by reading this manual and conducting any further research you deem necessary 
  3. Understand how the MLR affect you and what your responsibilities are 
  4. Implement Policies and Procedures concerning;

    a.    Client risk assessment and management

    b.    Client due diligence & ongoing monitoring

    c.    Record Keeping

    d.    Internal Control

    e.    Communication/Training for any staff

    f.     Reporting 

  5. Produce and sign a Policies and Procedures Statement (template can be downloaded from menu on the right)
  6. Add each client to your secure AML Online record and carry out a risk assessment for each 
  7. Complete the requisite Client Due Diligence checks, keeping a copy of the documentation you obtained and making a record of your checks on AML Online 
  8. Review and update your AML Online records for each client at least annually
  9. Review and update your policies and procedures at least annually (prompt sheet follows)


2. AML Procedures Annual Review checklist


Check Comments Checked By Checked On
Are all file copies of money laundering regulations current?      
Have all relevant staff including consultants, sub-contractors and temporary staff seen and agreed to abide by the practice's policies and procedures statement?      
Do procedures for client due diligence, record-keeping, internal and external reporting, internal control, risk assessment and management, internal communication and training comply with POCA and the current MLR? Are they operating satisfactorily?      
If you have staff, have all training assessments and other training records been reviewed?      
If you have staff, have all relevant persons signed a copy of the practice's money laundering compliance schedule?      

If you have staff, do all contracts of employment and agreements with consultants, sub-contractors and temporary staff contain the necessary references to money laundering?



3. Recognising potential money laundering - Prompt Sheet

Consider: Have any of the following been identified during the course of your work?

  1. Transactions that appear inconsistent with client's legitimate business activities
  2. Unusual deviations from normal account and transaction patterns.
  3. Transactions with little commercial logic that take place in the normal course of business.
  4. Complex corporate structure which does not seem necessary
  5. Unusually large and complex transactions, possibly with associated/ related third parties
  6. Unnecessary foreign travel  
  7. Unconventionally large currency transactions particularly in exchange for negotiable instruments
  8. Many large unexpected cash transactions
  9. Formation of companies or subsidiaries with no apparent commercial purpose
  10. Transactions with companies whose identity is difficult to establish or where they are registered in countries well known for their lack of proper financial control
  11. Unauthorised or improperly recorded transactions
  12. Any situation where personal identity is difficult to determine
  13. Transactions at under value
  14. Use of many different auditors and advisors for connected companies and businesses
  15. Sales reflected at less than cost putting company in a loss position but the company continues without reasonable explanation of the continued loss
  16. Client does not want correspondence sent to home
  17. Client uses a POB or general delivery address
  18. Client changes address frequently
  19. Client is secretive and reluctant to meet in person
  20. Client shows an uncommon curiosity about internal systems, controls, policies and reporting and has an unusual knowledge of the law in relation to SARs. 


Useful Forms

ICB is committed to provide full support to its members in practice. 

Below, please find various templates to enable Practice License holders to comply with their obligations under the Money Laundering Regulation 2007.

Money Laundering Regulations Compliance Policies and Procedures Statement

Client Risk Assessment

Client Due Diligence Record (individual)

Client Due Diligence Record (company/trust/charity)

Money Laundering Internal Report

MLRO Control Report Sheet

MLRO Report Log

Staff Training Record

If you have any queries or questions please do not hesitate to contact Matthew Burrell ICB's Compliance and Political Strategy Executive at or on 0845 060 2345

Please visit the ICB AML Online tool