Preparing for an AML Inspection
A practitioner's account of what actually happens before, during and after a supervisory inspection.
For CEOs, MLROs, Heads of Compliance, COOs, Risk Committee chairs and general counsel responsible for an upcoming or recent supervisory inspection.
Guide 006 sets out the practical work of inspection readiness. It covers what actually happens in the first 72 hours after a notice letter, how to clarify scope without conceding it, how to build a document request tracker and a single data room, how to read your own files cold before the regulator does, how to brief the Board and the executive, how to choose who speaks in interviews and rehearse honestly, what good looks like at the opening meeting and during the daily rhythm of the inspection, how to take notes at the exit meeting, how to respond to draft findings without negotiating away the truth, and what credible closure looks like in the year that decides the next supervisory letter.
Inside you will find
- The first 72 hours after a notice letter, and the cell that owns the inspection
- Clarifying scope, building an evidence request tracker and running a single data room
- Reading your own files cold before the regulator does; the pre-inspection file walk
- Briefing the Board and the executive; choosing who speaks and rehearsing honestly
- Day one, the daily rhythm, the exit meeting and what to take from it
- Responding to draft findings without negotiating away the truth; closing the loop credibly
- Appendix: a four-week preparation schedule and a working CEO briefing for day one
This is the guide I would hand to an MLRO the morning the notice letter arrives, and to a CEO the week before the inspectors are due in the building. It is not a primer on what a supervisor is entitled to ask. It describes the work: the documents you pull, the files you re-read, the rooms you book, the people you brief, the answers you rehearse and the questions you should already know the answer to before anyone walks in.
Fourteen sections, in the working order of an inspection cycle. The first five cover the weeks before. The next five cover the days in the building. The last four cover the weeks after, when most of the work that decides the supervisory outcome is actually done.
Structured to be useful, not to impress.
The first 72 hours after a notice letter, and the cell that owns the inspection
Clarifying scope, building an evidence request tracker and running a single data room
Reading your own files cold before the regulator does; the pre-inspection file walk
Briefing the Board and the executive; choosing who speaks and rehearsing honestly
Day one, the daily rhythm, the exit meeting and what to take from it
Responding to draft findings without negotiating away the truth; closing the loop credibly
Appendix: a four-week preparation schedule and a working CEO briefing for day one
10 Questions Every Board Should Ask Before the Regulator Does
Ten Board-level governance questions, with a structured self-assessment and score guide.
View guideIs Your AML Remediation Programme Set Up to Succeed?
Nine sections covering governance, quality assurance, MI, Board reporting and root cause analysis.
View guidePreparing for an AML Inspection
Eight focus areas from governance and CDD through to evidence preparation, with a readiness score.
View guideManaging an AML Remediation Programme
Fourteen working sections covering scope, governance, prioritisation, QA, MI, Board reporting and close-out.
View guideBoard Oversight of Financial Crime
Fourteen working sections on what the Board owns, the papers it reads, the questions it asks and the decisions it cannot delegate.
View guideQuality Assurance During KYC Remediation
Fourteen working sections covering sample design, defect taxonomy, calibration meetings, trend reporting, re-review triggers, acceptance criteria and how QA supports governance rather than only measuring it.
View guideBuilding Meaningful AML Management Information
Fourteen working sections covering the three lenses of activity, quality and residual risk, the five-question rebuild, KRIs and thresholds, the commentary discipline, escalation, the annual rebuild and how MI fails quietly.
View guideScoping an AML Remediation Programme
Fourteen working sections covering population definition, segmentation, the file standard, productivity pilots, capacity in layers, governance, mobilisation, dependencies, budget, contingency and the assumptions register that holds the plan together.
View guideIf you're unsure whether your organisation would benefit from external support, let's have a conversation.
If we don't believe Claritas is the right fit for your organisation, we'll tell you honestly.