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.
A Regulation 21 Audit is a regulatory requirement for most firms and it also:
🔹 Demonstrates a culture of compliance
🔹 A willingness to continuously improve
🔹 Identifies weaknesses before they attract scrutiny
🔹 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🔹 Over-reliance on outdated, generic templates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
By rolling it into next year, you are carrying forward risk, uncertainty, and vulnerability into another year. Is that how you want to begin 2026?
Recent findings show that where a Regulation 21 Audit is required but absent, it is viewed as a significant weakness in a firm’s governance and controls.
So, What Are The Benefits?
The Benefits of Compliance
🔹 You demonstrate to your regulator that you have considered Regulation 21
🔹 You show that you’ve assessed the size and nature of your firm — and acted accordingly
🔹 You define your independent audit function, scope, and process
🔹 You prepare properly, provide documents, and engage in the audit itself
🔹 You receive recommendations and create evidence of implementing them
🔹 You foster a culture of continuous improvement, not reactive fixes
🔹 Over time, you embed a rhythm and culture of compliance across the firm
A Regulation 21 Audit is not a burden. It is an investment in your firm’s resilience, credibility, and reputation.
Start the new year with assurance — not uncertainty.
Contact Us
At Alexander Christian, we offer a range of AML services including a Mock Audit that simulates a Formal Audit. It allows you to consider your current framework and make adjustments before a formal audit.
Book a consultation and talk freely about your needs.
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.