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AML Compliance · Small Law Firms · London · Alexander Christian

We help you know where your AML framework stands

For MLROs, compliance officers, and principals of small law firms in London who carry a quiet question they have not yet answered out loud.

Most people who arrive at this page are not in crisis. 

They are carrying something quieter than that,  an awareness that their AML framework has not been independently examined, and an uncertainty about what that examination would find. 

That feeling is more common than you know. And acting on it, before it becomes urgent, is exactly the right instinct.

We help you know where your AML framework stands

The question most MLROs carry

Not whether the framework exists.
Whether it would hold up

The policies are in place. The FWRA has been completed. The training has been done. But nobody independent has sat with the framework, looked at the files, spoken to the staff, and told you what they found, including the things that are uncomfortable to hear.


That is the gap this practice exists to close. An independent, external eye on your firm's AML position conducted without judgment, reported in plain language, and designed to tell you what you need to know rather than what is easiest to hear.


The right starting point depends on where your firm is. The initial consultation is the space to work that out together.

"You are so busy doing billable work and wearing multiple hats that you cannot find the unbillable time to address the non-billable, high-stakes compliance work."


We know you are busy. That is not a criticism it is the structural reality of a small firm. We are here to provide the independent examination that frees you from the uncertainty of not knowing where your framework stands.

Not whether the framework exists. Whether it would hold up

Who this is for

The compliance responsibility in a small firm is carried by people not systems.

The regulations do not fall on the firm as an abstract entity. They fall on the individuals responsible for implementing and maintaining the framework. This section is written for those people directly.

The MLRO

You are doing the compliance work and the fee-earning work simultaneously. Responsible for the AML framework, for training, for supervising SARs, for keeping the FWRA current whilst also carrying a caseload and serving clients.


The compliance work does not stop because the billable work is busy. And the anxiety of not knowing whether the framework is adequate does not stop either.


"I know I should have had this examined. I just have not found the time."

The MLRO

The sole principal or senior partner

You are ultimately responsible and you know it but the day-to-day falls elsewhere. Your oversight may be lighter than it should be, and you carry the personal regulatory exposure that comes with that.


Commissioning an audit feels like opening a door you are not sure you want to open. But the risk of not opening it is greater than the risk of what is behind it.


"I know we need to do this. I have been putting it off."

The sole principal or senior partner

The compliance officer

You know the framework and you know where it is weakest. The areas where practice does not match policy. Where fee earners take shortcuts under time pressure. Where the FWRA has not been updated to reflect changes in the firm's work.


You want an independent view that validates what you already suspect and gives you the documented basis to act on it.


"I know where the gaps are. I need someone independent to confirm them."

The compliance officer

The three ways we work with firms

The right starting point depends on where your firm is.

The initial consultation is the conversation that identifies the most proportionate starting point for your situation. What follows from that conversation is one of three paths.

For the firm that needs to evidence compliance

The Regulation 21 independent audit

Find out more

Chosen by the firm that needs to fulfil its statutory obligation under Regulation 21(1)(c) of the Money Laundering Regulations 2017.


A formal independent audit of the firm's AML framework examining adequacy, effectiveness, and compliance. The report states what is found. Findings are not softened. Recommendations are practical.

This is the audit that produces a documented record. It is not a preview. It is the formal engagement.

For the firm that wants to know before it has to

The mock audit

Find out more

Chosen by the firm that wants to know ... before any formal process begins.


The mock audit is conducted to the same rigour as the formal audit. The difference is the status of the output. A mock audit finding is not a regulatory document. It is a clear picture of where the framework stands, used by the firm to strengthen before the formal engagement.


Mock audit and formal audit together form the most robust path. Mock audit prepares you. Regulation 21 audit evidences you.

Three uses one service

Document and file review

Find out more

The file review serves three distinct purposes depending on where the firm is. Understanding which applies is part of the initial consultation.


As a first step for the firm considering an audit. Before committing to the fuller Regulation 21 process, a file review gives an early indicator of whether the framework is working in practice. Whether CDD is being completed. Whether risk assessments are proportionate. Whether the files reflect the policies. It is scoped and limited it cannot substitute for the full audit but it tells the firm enough to make a more informed decision about the right next step.


As an ongoing monitoring process. For the firm that has completed an audit and wants to maintain its position between formal audit cycles. Periodic file reviews evidence that the framework is not just documented but embedded and working on live files. This is the continuous assurance obligation that sits alongside the formal audit not a one-time event but a regular part of how the firm manages its compliance position.


As a standalone engagement. For the firm that wants an objective external view of whether its current files meet its own CDD policies without the full audit process and at a proportionate cost.


All file reviews produce a written note of findings and practical recommendations. Scope is agreed before the engagement begins.

The Regulation 21 independent audit
The mock audit

The regulatory context

151

AML enforcement outcomes recorded by the SRA in its 2024-25 Annual Report

The firms caught were not
rogue operators.

They were ordinary practices whose frameworks were adequate on paper and inadequate in practice. The gap between the two is precisely what an independent audit is designed to identify and close.


The SRA's enforcement enlightens us.


A documented, independently verified AML position is not just a regulatory requirement. It is the evidence that your firm took its obligations seriously available when it matters most.

The first step

An initial consultation.
Not a sales call. A professional conversation.

The initial consultation is a paid, in-person professional conversation about your firm's current position and the most proportionate starting point for your situation.


No obligation to proceed with anything further. Many firms find the conversation itself clarifying enough to know what they want to do next.

The consultation fee is not offset against the cost of any subsequent engagement. It is a professional conversation with real value in its own right, regardless of what follows.


At the end of the consultation, one of three outcomes will be clear. This is the right engagement at the right time. This is the right engagement but not yet the right time. Or this is not the right engagement in which case you will be told clearly and pointed toward what would better serve your position.

We help you know.

Not what you want to hear. What you need to know. The firms that commission an independent examination of their AML position before it becomes urgent are the firms that are in control of their regulatory story rather than responding to someone else's version of it.


Acting on the quiet question before it becomes a loud one is the right instinct. 


The initial consultation is where that process begins.


All AML fees are bespoke fixed fees agreed before any engagement begins. See our fees page for details.

We help you know

Your AML framework.
Examined independently.


What you need to know. Stated directly.

A paid initial consultation about your firm's current position and the most proportionate starting point for your situation. 


No obligation to proceed. 

Your AML framework. Examined independently.

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Get in Touch at Any Time

Do not hesitate to contact us with any queries.

Alexander Christian

Harrow Business Centre

429-433 Pinner Road

North Harrow

Middlesex

Greater London

HA1 4HN

Phone : 020 4578 4684

www.alexanderchristian.co.uk

Topics and search terms

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