Will this be the AML Ghost that Revisits you Next Year?
More forward to next year - having progressed your compliance
The Ghost of Regulation 21
As the year draws to a close, it’s worth asking: has your firm completed its Regulation 21 Audit?
Too often, small firms delay — waiting for the “right time,” or believing that because no issues have surfaced, an audit can wait. But time passes quickly. Another year ends, and with it, another missed opportunity to strengthen your AML framework.
👉 Don’t carry the ghost of unfinished compliance into another year.
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Why Firms Delay
What delays often look like in practice:
🔹 Complacency or false confidence in existing processes
🔹 Over-reliance on outdated, generic templates
🔹 Assuming a FWRA and policies alone are “enough”
🔹 Dismissing the Regulation 21 Audit as unimportant
The result? By rolling it into next year, you are carrying forward risk, uncertainty, and vulnerability into 2026.
👉 Is that really how you want to begin the new year?
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Why Regulation 21 Matters
A Regulation 21 Audit is more than a regulatory requirement. Done properly, it:
🔹 Demonstrates a culture of compliance
🔹 Shows willingness to continuously improve
🔹 Identifies weaknesses before they attract scrutiny
🔹 Builds credibility with regulators, banks, and counterparties
Recent findings show that when a Regulation 21 Audit is required but absent, it is viewed as a serious weakness in a firm’s governance and controls.
👉 The regulator doesn’t see “delay” — they see “deficiency.”
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So, What Are The Benefits?
The Benefits of Compliance
When you take Regulation 21 seriously, you:
🔹 Demonstrate to your regulator that you’ve acted with care
🔹 Define your independent audit function, scope, and process
🔹 Prepare properly, provide documents, and engage proactively
🔹 Receive recommendations and evidence their implementation
🔹 Foster a culture of continuous improvement, not reactive fixes
🔹 Embed a rhythm and culture of compliance across the firm
A Regulation 21 Audit is not a burden. It is an investment in resilience, credibility, and reputation.
👉 Assurance is the best way to start the year.
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Contact Us
Next Step: From Ghosts to Confidence
At Alexander Christian, we provide AML solutions for discerning small firms. Our Mock Audit service simulates a formal audit — allowing you to test, refine, and strengthen your framework before a regulator arrives.
🎯 Start 2026 with assurance, not uncertainty.
[Book your confidential consultation today]
Disclaimer
This post is not legal or regulatory advice, nor is it to be construed as such. If you require individual legal or regulatory advice for your individual circumstances you should see a provider who has agreed to provide such advice to you.