Anti-Money Laundering (AML) Policy Writers

What are Anti-Money Laundering (AML) Policies?

Anti-money laundering (AML) policies outline how organisations prevent, detect and report activities that may involve money laundering, terrorist financing or other financial crime.

Money laundering can expose organisations to serious legal, financial and reputational risks. A clear policy ensures that staff understand their responsibilities, that suspicious activities are identified early, and that the organisation complies with all regulatory requirements.

What Do Anti-Money Laundering Policies Cover?

An anti-money laundering policy typically includes:

• A statement of zero tolerance towards money laundering and financial crime

• Responsibilities of staff, managers and nominated officers (such as a Money Laundering Reporting Officer, MLRO)

• Customer due diligence (CDD) and know your customer (KYC) requirements

• Risk assessment processes to identify high-risk clients, transactions or jurisdictions

• Procedures for identifying and reporting suspicious activity to the MLRO

• Record-keeping requirements for transactions and due diligence checks

• Staff training on recognising and responding to money laundering risks

• Cooperation with regulators and law enforcement agencies where required

• Links to financial crime, bribery and corruption, fraud prevention and compliance policies

A clear policy helps employees understand how to spot red flags, follow reporting procedures and act responsibly when handling client transactions or financial matters.

It also ensures compliance with the UK Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Proceeds of Crime Act 2002 and oversight from bodies such as the Financial Conduct Authority (FCA).

By embedding robust AML practices, organisations can reduce exposure to financial crime, protect their reputation and demonstrate their commitment to lawful and ethical business conduct.

Legal Basis

The framework is the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLRs), the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Criminal Finances Act 2017.

Supervisory authorities include HMRC, FCA, the SRA, ICAEW and other professional bodies depending on sector.

The Economic Crime and Corporate Transparency Act 2023 introduced the new corporate offence of failure to prevent fraud (in force from 1 September 2025) which interacts directly with AML controls. See our failure to prevent fraud and UK Fraud Strategy 2026 employer guide for the in-scope thresholds, the six reasonable procedures principles and how the framework sits alongside AML and anti-bribery obligations.

Common Compliance Pitfalls

• Risk assessment generic across the firm rather than client-by-client and matter-by-matter.
• Customer Due Diligence (CDD) treated as identity verification only, missing source-of-funds and source-of-wealth.
• Politically Exposed Person (PEP) checks limited to UK PEPs, not domestic-PEP-extension scope (since 2022 changes).
• Suspicious Activity Reports (SARs) under-submitted for fear of tipping off.
• Training delivered annually but not refreshed for sector-specific typologies (e.g. property, art market, crypto).

What Policy Pros Delivers

Our AML Policy package includes the main policy, a firm-wide risk assessment, a CDD procedure with EDD triggers, a PEP and sanctions screening procedure, a SAR procedure with NCA submission template, a training programme, and integration with the Anti-Bribery, Sanctions and Failure to Prevent Fraud policies.