Prepping can provide Insight
For many important aspects of life, preparation is important, so why not prep for a formal audit?
Preparation Brings Clarity
In most aspects of life, preparation matters. The same is true of compliance. If you wouldn’t walk into a critical meeting unprepared, why approach a formal AML audit any differently?
For many small law firms, Anti-Money Laundering compliance is something that ticks along quietly in the background. Policies are in place, checklists are used, files are opened - and, on the surface, all appears well.
Yet when asked the simple question - “When did your firm last conduct an AML audit under Regulation 21(1)?” - there is often uncomfortable movements and awkwardness.
Some firms have never undertaken one. Others worry about what might be uncovered. And many tell themselves they’ll address it “next year.”
The difficulty is, regulators are not waiting.
The Quiet Risks of Doing Nothing
Even well-run firms can drift from best practice. Updates are missed, templates are relied upon too heavily, policies are left generic, or risk assessments become routine tick-boxes rather than thoughtful exercises.
None of these may seem fatal. After all, something is in place. But in reality, it amounts to coasting - and coasting is not a strategy.
Regulators increasingly regard the absence of a Regulation 21 audit as a significant failing in governance and control.
What a Mock Audit Really Is
A mock audit is not a formal Regulation 21 audit. It is a voluntary, independent review conducted in a safe environment.
Think of it as a rehearsal:
Simulating a formal assessment
Highlighting weaknesses discreetly
Offering the chance to act before findings are official
It is your opportunity to test your framework, close gaps, and demonstrate a genuine commitment to continuous improvement.
The Benefits for Your Firm
Three immediate benefits:
Peace of mind — replacing maybe constant worry with more understanding of the process, becoming less siloed, and more responsive to change
Early insight — identifying gaps while they are still manageable
Stronger culture — demonstrating to stakeholders, that your firm's governance is robust, and is engaged with continuous development of your AML framework
You will engage in conversations that help you grow your AML confidence
A Step Towards Certainty
Many small firms hesitate - fearing either the process or what might be found. A discreet, independent mock audit is not about criticism; it is about insight. It equips you to meet your obligations, strengthen your practice.
So, if you are prepping for a formal audit and want an independent set of eyes, then a Mock Audit may be something to consider.
Take the Next Step
If your firm has not undertaken an AML audit under Regulation 21, or if your framework has not been reviewed in years, now may be the moment to act.
At Alexander Christian, we offer confidential mock audits that provide clear, practical insights without the weight of formal findings.
Because in AML compliance, prevention is not just prudent — it is essential.
Disclaimer
Be aware that a mock audit is not a legal or regulatory requirement. It is not a substitute for a formal regulatory - Regulation 21(1) (c) Audit. Failure to have a Regulation 21 (1) (c) where it is appropriate can lead to fines and penalties.
This post is not legal or regulatory advice, nor is it to be construed as such. For legal and regulatory advice relevant to your individual circumstances please instruct your own appropriately qualified representative.