Keep an AML file and sign it off

Record parties and screenings, get a computed risk rating and sign the file off for inspection.

The AML register lists every client's AML file. Each file holds the client relationship, the parties involved, screening history and a risk rating.

1. Open the client's AML file.
2. Add the parties, including beneficial owners at 25% or more.
3. Record each screening. New screenings are stamped with who recorded them, and the history is never shortened.
4. Tick the risk factors that apply. The rating is worked out from named factors, such as a politically exposed person, a listed jurisdiction, layered ownership or proliferation financing exposure.
5. Write the rating rationale. You may override the rating, but only with a written reason.
6. Sign the file off as MLRO.

The sign-off is tied to the file as it stood. If a party, the rating or a screening changes later, the sign-off shows as no longer valid until it is signed again.

Review is due every 12 months for high risk, 24 for medium and 36 for low. Suspicious transaction reports filed through goAML can be logged on the file.