Use this toolkit to create an AML Evidence Pack for your firm. This pack brings together downloadable documents, reports, and records you may need for an AML audit, inspection, or internal compliance review.
The aim is to help you show that your AML approach is tailored to your firm, supported by evidence, and kept up to date.
This guide is designed to help you organise common AML evidence in one place. It is not a complete list of everything your firm may need for an audit, inspection, or regulatory review. Your firm remains responsible for making sure its AML framework is appropriate to its size, services, clients, and risk profile.
Evidence Item | What to Check | Firmcheck Action |
Tailored PCP | Your Policies, Controls, and Procedures reflect how your firm actually manages AML risk. | Check that your Firmcheck workflow matches your written AML procedures, and upload your PCP to Firmcheck here. |
Tailored FWRA | Your Firm-Wide Risk Assessment reflects your firm’s clients, services, matters, and risks. | Compare your FWRA against your Firmcheck risk assessment setup. |
CDD report | You can evidence client risk levels, addresses, and CDD status across the firm. | Export your CDD report from Firmcheck and save it in your AML Evidence Pack. |
AML education records | Relevant staff have completed AML education, and you have evidence of this. | Complete AML education in Firmcheck, and download certificates. |
Relevant risk questions | Your risk questions reflect the work your firm actually does. | Review your Firmcheck risk assessment questions and update them where needed. |
FWRA review evidence | You can show when your FWRA was last reviewed, and what changed. | Document changes to your FWRA (Firmcheck saves previous versions of your document to help create an audit trail). |
Your Firmcheck risk assessment questions should match your firm’s actual risk profile.
For example, ask yourself:
If you act for insurance companies, should a question specific to this industry be included as a risk question?
If you work with overseas clients, do your questions capture jurisdiction risk?
If you handle high-value transactions, do your questions capture source of funds risk?
If you act for companies or trusts, do your questions capture ownership and control risk?
Keep a short note explaining why your key risk questions are relevant to your firm. This can be added to your Policies, Controls, and Procedures document.
Create a folder called AML Evidence Pack, and save:
PCP
FWRA
Firmcheck CDD report
AML education certificates
Risk assessment question relevance notes
FWRA review history
Before using your AML Evidence Pack as part of audit or inspection preparation, check that you can answer yes to the following:
Is our PCP tailored to how our firm works?
Is our FWRA tailored to our actual risks?
Do our Firmcheck risk questions match our FWRA?
Have we exported client risk levels and address data?
Can we evidence AML education completion?
Can we show when our AML framework was last reviewed?
If not, update the relevant item before using the pack for audit or inspection readiness.