“...The challenge today is implementation, implementation, implementation – in short, effective and efficient action by the public and private sectors acting in partnership to stop money laundering; to reduce the harm caused by crime and terrorism.” –
David Lewis, former Executive Secretary of the Financial Action Task Force (FATF)
This Keynote speech by David Lewis, FATF Former Executive Secretary was delivered at the 7th International Anti-Money Laundering and Compliance Conference:
'Fighting Financial Crime'
Bratislava, 10-11 December 2019
Book your free 15-minute chat*
We offer a 15-minute no-obligation chat
💬 Complete the form below
Independent Internal Audit
Regulation 21: More Than a Regulatory Obligation
Under Regulation 21(1)(c) of the Money Laundering Regulations 2017, firms are required—where appropriate to their size and nature—to establish an independent audit function. But this isn't just a box-ticking exercise.
It's a vital safeguard—designed to ensure your AML framework is more than just policy on paper. An effective independent audit brings transparency, identifies gaps, and strengthens governance.
Non-Compliance with Regulation 21(1)(c) requirement
Recent SRA enforcement action has brought Regulation 21(1)(c) — the requirement for independent internal AML audits — sharply into focus.
A firm's recent failure in this area, as detailed in an SRA outcome, serves as a stark reminder: compliance with all parts of the Money Laundering Regulations is not optional, and non-compliance carries real regulatory repercussions.
This is often the primary document the regulator will ask for. Your failure to produce one without a documented explanation will likely lead to further questions.
Why start off your regulatory inspection on the wrong foot?
- It's a vital part of your controls and points to good governance.
- While meeting a mandatory requirement is paramount, the benefits of an independent audit extend far beyond mere box-ticking. Gaining an objective perspective on your AML programme can illuminate opportunities for significant improvement and bolster your defences against financial crime.
- Firms, operating in their own bubble, can sometimes develop blind spots and, despite their best intentions, may overlook critical compliance gaps.
- The sooner you embrace this independent review, the more resilient your firm will be in combating illicit financial activity.
Why Choose Alexander Christian as Your Independent Auditor?
✅ Unbiased Perspective
Internal reviews can be influenced by internal culture, assumptions, and pressures. Our audits offer a fresh, unbiased assessment, free from internal blind spots or conflicts of interest.
✅ Sector-Specific AML Expertise
We bring deep insight into the legal sector’s AML compliance landscape, aligning our audit approach with current LSAG guidance and evolving regulatory expectations.
✅ Actionable, Tailored Recommendations
Our reports don't just flag issues—we provide tailored, practical solutions that support continuous improvement and reduce compliance risk.
✅ Enhanced Regulatory Confidence
Demonstrating commitment to independent scrutiny signals to regulators your serious approach to AML compliance. This is especially valuable during inspections or inquiries.
Regulation 21(1)(c)(ii) and (iii) require that audits include recommendations and monitor follow-up. We offer support beyond the report, helping you implement changes and ensure they stick.
Typical Triggers for Instructing an Independent AML Audit:
- Preparing for an SRA or HMRC inspection
- Addressing internal concerns around AML controls
- Seeking assurance before onboarding a new MLRO or senior management
- Reassessing risk exposure after changes in firm structure or services
- Aligning with the 36 LSAG High-Level Compliance Principles
Our Audit Services Include:
- Full Regulation 21 Independent Audit
- Mock Regulation 21 Audit (ideal as a diagnostic or rehearsal for inspection)
- Focused Audits (targeting high-risk areas such as Source of Funds or CDD)
- Staff AML Interviews to assess awareness and training effectiveness
- File Reviews to assess implementation of PCPs in real-time scenarios
Our Process
Let’s Talk — No Pressure, Just Insight
We offer a confidential, free 15-minute consultation to help you assess your position and consider next steps.
📞 Call us on 020 4578 4684
✉️ Or contact us online to get started
About Alexander Christian
At Alexander Christian we support regulated professionals with AML compliance, governance, and internal assurance.
We are members of the ICA and the ACAMs and have attended many risk and compliance courses and attained accreditations.
Our blogs
Explore our blogs on Anti-Money Laundering, Sanctions, AML Acronyms, SRA guidance, FATF and more
Non-compliance? - No independent internal audit?
Failure to establish an independent internal audit function, can lead to your regulator concluding that you have failed to comply with an internal control.
Legal Sector Affinity Group Update April 2025
April 2025 saw an update to LSAG. Read our key takeaways.
Do you want a confidential chat to discuss your AML framework. No judgment and no obligation. Contact us.
Why AML Mock Audits
Why an AML Audit is a vital part of your AML Defence.
Don't let compliancy lead to disaster.
Compliance Doesn’t Have to Be Complicated
Whether you're seeking an audit, or other AML service, we’re here to make compliance feel clear, manageable, and even empowering.
No jargon. No pressure. Just support tailored to your business.
💬 Complete the form below, and we’ll help you take control of your AML responsibilities with confidence.
Contact Us
See our Privacy Page
See our Client Due Diligence Page
See our Pre-onboarding Page
See our Fees Overview Page
Call Us: 020 4578 4684