AML Mock Audits for Law Firms
Mock Audit,
Practical Insight.
AML Mock Audits:
An AML Mock Audit is a proactive, informal review of your AML framework, designed to simulate the scrutiny of a formal Regulation 21 audit . It helps your firm identify weaknesses, validate strengths—in a confidential setting.
Key benefits:
Helps you anticipate and meet regulator expectations
Tailored to your firm’s needs: full-system review or focused sampling
Delivers practical, actionable insights—before issues become liabilities
What is a Mock AML Audit?
A mock audit is a voluntary, internal or outsourced review, often commissioned proactively by firms to prepare for regulatory scrutiny or to identify weaknesses before they become formal findings.
Key features:
Not required by law, but provide insight
Helps firms assess their AML compliance in a low-risk environment.
Often simulates what a Regulation 21 auditor might assess.
Allows firms to identify and address issues before a real audit or inspection.
Why Commission a Mock Audit?
Why Commission a Mock Audit?
Firms often face AML challenges in silence—only addressing weaknesses once an audit is triggered or a regulator intervenes. A mock audit flips the script, giving you a chance to strengthen your position before you’re under the spotlight.
Benefits of a mock audit
| Benefit | Description |
|---|---|
| Early Risk Detection | Identify gaps in your AML systems, policies, and client files before they escalate. |
| Stronger Internal Controls | Test and refine your Policies, Controls and Procedures (PCPs) in practice. |
| Regulatory Readiness | Prepare thoroughly for a Regulation 21 audit, reducing anxiety and disruption. |
| Team Confidence | Reinforce staff awareness and application of AML responsibilities. |
| Demonstrate Best Practice | Show regulators you’re not just compliant—you’re committed to ongoing improvement. |
Regulation 21 Audit vs. Mock Audit
| Feature | Regulation 21 Audit | Mock AML Audit |
|---|---|---|
| Legal Status | Mandatory under MLR 2017 | Voluntary |
| Purpose | Independent assessment of AML framework | Preparation, gap analysis, internal assurance |
| Scope | Entire AML framework and effectiveness | Full or focused (e.g., file reviews, policies, training) |
| Outcome | Formal report for regulatory file | Informal feedback or structured action plan |
| Regulatory Weight | Required by regulators | Not mandatory, but may support assurance conversations |
What We Review
Mock audits are bespoke and scoped to your priorities. We can assess:
Whether your AML policies are proportionate and being followed in practice
The quality and consistency of client and matter risk assessments
Sanctions and adverse media screening procedures
Internal reporting pathways (e.g., suspicions, SARs)
Training records and staff AML awareness
Your documentation and record-keeping obligations
All findings are presented with practical, proportionate recommendations—aligned with your firm’s Firm-Wide Risk Assessment (FWRA) and existing workflows
Confidential. Discreet. Tailored to Your Firm.
At Alexander Christian, we understand the regulatory and reputational pressures faced by law firms. Our AML mock audits are:
Confidential – conducted with discretion and professionalism
Constructive – feedback is practical, not fault-finding
Flexible – scoped to your concerns, risk areas, or audit preparation needs
Supportive – we offer follow-up guidance and remediation support if needed
Ready to Review Before You're Reviewed?
Commissioning a mock audit is a smart, risk-based investment in your firm’s compliance health. Whether you’re preparing for a Regulation 21 audit, seeking internal assurance, or want peace of mind that your AML framework is fit for purpose—we’re here to help.
Book a confidential consultation today.