UK AML hub · Practical process
AML Checks on Existing Clients: Clearing a Backlog
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What your process needs to cover
- Define the scope, responsible person, required evidence, approval route and risk-based review trigger for the firm's actual clients and services.
- Record the evidence considered, the decision reached, the responsible person and the date of the next risk-based review.
- Follow the current Money Laundering Regulations 2017, CCAB guidance and any additional direction issued by the firm's own supervisor.
- Escalate unusual facts and higher-risk relationships rather than forcing every client through the same generic checklist.
Six-stage workflow
A practical AML process your team can follow
- Stage 1
Start with scope and ownership
Confirm which clients and services are affected by aml checks on existing clients: clearing a backlog, then appoint a named owner with authority to obtain information and escalate concerns.
- Stage 2
Gather reliable evidence
Collect the identity, ownership, purpose, source-of-funds and relationship information required by the risk. Use Remindoo's built-in digital ID verification and screening where electronic checks are needed.
- Stage 3
Assess risk and explain the rationale
Consider client, service, delivery-channel and geographic factors together. Record why the final rating is proportionate instead of relying on a score alone.
- Stage 4
Apply proportionate controls
Complete standard, simplified or enhanced work only where the law and the recorded risk support it. Obtain approval where the firm’s procedure requires it.
- Stage 5
Keep one dated record
Store the evidence, judgement, approval, communications and next action together so another authorised person can understand the file.
- Stage 6
Monitor and re-assess
Set a risk-based review date and trigger an earlier review when ownership, activity, geography, instructions or other relevant circumstances change.
Worked risk examples
| Level | Scenario | Proportionate response |
|---|---|---|
| Lower risk example | A familiar UK trading company with straightforward ownership and activity consistent with the information supplied. | Apply documented, proportionate CDD and ongoing monitoring. Lower risk is not no risk, and the rationale still needs recording. |
| Medium risk example | A remote client with a less familiar business model or cross-border element that is credible but needs additional explanation. | Obtain enough corroborating evidence, resolve inconsistencies and set a more attentive review cycle. |
| Higher risk example | A complex or unusually large transaction, opaque ownership, unexplained source of funds or another factor identified by law or guidance. | Escalate, apply EDD where required, obtain appropriate approval and consider reporting duties without alerting the client. |
Common monitoring findings
- A generic risk assessment that does not match the firm or client
- Missing evidence for identity, ownership, source of funds or the decision reached
- Reviews completed late, with no trigger-based re-assessment after material change
- Policies that describe controls the client files do not evidence
- Staff unable to explain the internal escalation and SAR process
Keep AML work visible alongside every client
See manual risk records, recurring reviews and client evidence in one practice workflow.
Where Remindoo fits
Your AML process in the same place as your clients, tasks and deadlines — no separate system for risk assessments, records and reviews. Remindoo manages your AML risk assessments, records and review schedule. Electronic ID and AML screening are built in, charged per check.
- AML risk scoring and digital ID checksRisk assessments plus built-in digital KYC, AML and proof-of-address checks.
- Centralised client informationServices, documents and notes in one record.
- Client timelineFull history of notes, emails and actions.
- Recurring tasksRepeat work is created automatically on schedule.
- Task and subtask templatesChecklists that make every job consistent.
AML plan inclusion: [CONFIRM WITH REMINDOO TEAM].
Free AML Essentials Kit
Put the process into practice
Download the matching editable resource through the existing secure resource flow. No email delivery is used.
Get AML Essentials KitFrequently asked questions
Does Remindoo complete this AML work automatically?
Remindoo records assessments, evidence and review tasks. It also has built-in digital identity verification, liveness and face matching, AML screening and continuous monitoring, charged per check.
Can software make an accountancy firm fully AML compliant?
No. Compliance depends on the firm’s risk assessment, policies, evidence, judgement, training, supervision and response to suspicious activity.
Which guidance should our firm follow?
Follow the Money Laundering Regulations 2017 as amended, current CCAB guidance and the current guidance of the body that supervises your firm.
How often should the record be reviewed?
Use a documented risk-based schedule and review sooner when relevant client circumstances, ownership, activity, instructions or risk factors change.
Can Companies House data replace CDD?
No. Companies House information is useful evidence and a cross-check, but it does not remove the duty to identify, verify and understand the client and beneficial owners.
Where does electronic ID and screening happen?
Inside Remindoo. The client completes digital ID and screening checks from an emailed link, and the outcome is saved to their AML record.
Build a calmer, review-ready AML process
Try Remindoo free for 60 days, or book a demo to see manual AML recording and recurring reviews.
Primary sources
Last updated 24 September 2026. General guidance, not legal advice. Follow your supervisor's guidance.
