Get ahead of your Anti-Money Laundering (AML) Regulation 21 Audit, with a Mock Audit
Why a Mock AML Audit Is a Smart Compliance Strategy
Discover how a Mock AML Audit can help your regulated firm identify gaps, strengthen compliance, and confidently prepare for your next Regulation 21 AML audit.
Regulated Firms—those operating under the Money Laundering Regulations 2017—have a legal obligation to implement robust Anti-Money Laundering (AML) controls. These regulations aren’t optional. They’re enforceable, and failure to comply can lead to regulatory penalties, reputational damage, or in some cases, criminal prosecution.
One key requirement—often overlooked or underprepared for—is the need for an Independent Internal Audit of the regulated firm's AML framework, subject to the regulated firm’s size and nature.
And importantly: this Regulation 21 internal audit must be made available to your relevant regulator.
Have you ever thought about a Mock AML Audit? A Mock AML Audit gives regulated firms the chance to review, test, and improve their AML programme before the formal Regulation 21 independent internal audit or regulatory inspection.
⚖️ Is Your AML Compliance Truly Audit-Ready?
⌛Don’t wait for a regulatory review to uncover what you could have addressed today.
⌛AML compliance is not a one-off requirement—it’s a dynamic process of continuous improvement.
⏳A Mock AML Audit offers valuable insights, enhances your internal controls, and demonstrates your firm’s commitment to best practices.
✨ Protect your reputation. Strengthen your systems. Stay ahead of the curve.
♾️ It’s an ongoing process. A cycle of review, refinement, and improvement.
♾️That’s where a Mock AML Audit comes in.
♾️It gives you the insight, clarity, and confidence you need—before regulators get involved.
AML Compliance Isn’t a One-and-Done Task
♾️It’s an ongoing process. A cycle of review, refinement, and improvement.
♾️That’s where a Mock AML Audit comes in.
♾️It gives you the insight, clarity, and confidence you need—before regulators get involved.
A Smart Move for Firms
🤷🏼 Maybe you've a regulated firm under the Money Laundering Regulations and feeling uncertain about the current state of your AML programme?
🤷🏼 Maybe you’ve an Money Laundering Reporting Officer (MLRO) and inherited someone else’s AML framework.
🤷🏼 Maybe it’s been a while since your last review, or you're simply looking for a proactive assessment ahead of your next mandatory Regulation 21 audit.
🤷🏼 If you’re new to the role of MLRO—or have recently taken on AML or compliance responsibilities—it’s entirely reasonable to seek a fresh, independent perspective. Stepping into someone else’s shoes can be challenging, and having that “second sight” can provide the clarity and confidence you need to move forward with assurance.
Can you answer these questions without reservation?
🎯Policies, Controls & Procedures (PCPs): Are they current, complete, and truly implemented?
🎯CDD & EDD Processes: Are your due diligence practices robust and regulation-ready?
🎯Firm-Wide Risk Assessment: Is it documented, data-driven, and influencing your AML strategy?
🎯Staff Training: Does your team know their AML responsibilities and how to act?
🎯Record Keeping: Are your records accessible, accurate, and audit-ready?
🎯Suspicious Activity Reporting: Do your internal systems catch and report issues efficiently?
Why a Mock Audit Works?
🫱🏻🫲🏼Unlike formal audits, a mock audit encourages collaboration, honesty, and growth.
💡No judgment. Just practical insight you can act on.
🔑Because it is a mock there tends to be a greater degree of collaboration and frankness: This actually assists to delve deeper and creates an environment for greater openness and growth
🔑Spot Weaknesses Early: it can help to identify gaps before the regulator does.
🔑Strengthen Your Compliance: it can help you to fine-tune your AML framework and meet—or exceed—regulatory standards.
🔑Build Internal Confidence: it can provide you with recommendations
🔑Support for Regulation 21 Audits: the mock findings can help you to prepare thoroughly for formal reviews.
🔑Demonstrate Proactivity: it can help show your commitment to staying compliant and reducing risk.
Important: A Mock AML Audit offers valuable insights, but it’s not a substitute for a Regulation 21 AML Audit. A Mock AML Audit is a limited snapshot of your framework and implementation, but it can provide independent insights that you would not otherwise have. Responsibility for AML compliance always remains with your firm.
The True Cost of a Weak AML Framework
Non-compliance with Anti-Money Laundering obligations isn’t just a technical failure—it’s a reputational and legal risk.
Regulated Firms are expected to operate as a strong line of defence against financial crime. Falling short—intentionally or not—can have serious consequences:
🚫 Regulatory Fines: Regulators are increasingly taking action against firms with weak AML controls, and penalties are rising.
⚠️ Being Branded a “Professional Enabler”: Firms seen as soft-touch targets may attract the wrong kind of attention—from criminals and regulators.
🏛 Criminal Conviction: In severe cases, failures can lead to prosecution, disqualification, or even imprisonment.
💥 Reputation Damage: Once lost, trust with clients, colleagues, and your professional regulator is incredibly hard to rebuild.
🕳 Operational Disruption: Investigations and remedial actions drain time, energy, and focus from your core business
You Wouldn’t Sit an Important Exam Without Doing Practice Questions —
So Why Face a AML Regulatory Audit Without a Mock?
💯 Knowing the rules isn’t enough. Just like in exams, you need to test yourself under realistic conditions to identify weak spots, sharpen your approach, and build confidence.
💯 A Mock AML Audit does exactly that—giving you a safe space to find and fix issues before it really counts.
💯 Does this resonate with you?
Still Feeling Unsure? That’s Okay.
🪫If you’ve read this far, there’s likely a reason.
🪫Maybe it’s a quiet concern you’ve been meaning to address.
🪫Or a sense that you should be doing more.
That instinct is worth listening to.
🔋 We’re not here to sell—we’re here to help.
Let's Talk
☎️Whether you need clarity, a second opinion, or just a place to start, we’re here.
☎️Get in touch for a no-pressure conversation.
Anti-Money Laundering Phrases and Acronyms
🔤On this page you will find reference to some phases and acronyms, which are frequently used in AML. We have just set them out for easy of reference.
| Anti-Money Laundering Phrase or Acronym | Information |
| AML | Anti-Money Laundering |
| CDD | Client or customer due diligence, some times referred to as standard due diligence |
| EDD | Enhanced Due Diligence, this is used when there is a heighted risk or in specific circumstances for example the subject is a politically exposed person, or there are connections to high risk third countries |
| FWRA | Firm Wide Risk Assessment also referred to PWRA Practice Wide Risk Assessment. It is a regulatory requirement to have a FWRA/PWRA |
| Mock AML Audit | This is can be a bespoke or simulated Anti-Money Laundering Audit |
| Money Laundering Regulations 2017 | Short hand reference similar to MLR, MLR17, it refers to Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 |
| PCPs | Policies, Controls and Procedures these relate to the regulated persons internal anti-money laundering policies, controls and procedures |
| Regulation 21 Audit | Refers to the Regulation 21 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. |
FAQ
Further Reading
🔖Explore our pages and blogs
Alexander Christian - Anti-Money Laundering - Overview of Services
Explore our services in our Anti-Money Laundering - Overview of Services page
Alexander Christian - Regulation 21 Audit
Regulated persons are required to have a Regulation 21 Independent Internal Audit subject to the size and nature of their business.