Part 2 of a 3-part series. Part 1 covered why AML programmes fail even when the policy is sound: not at the design stage, at execution. Of the six cogs that keep a programme running (Clarity, Capacity, Communication, Commitment, Consistency, Culture), this post is about getting the first three actually turning.
Start by finding out what's really happening
You can't redesign a programme you haven't honestly audited. That means training for the people running it, not just regulatory updates, but how to do the job from first principles. It means documenting the firm's actual risk appetite and matching it to the people implementing it. And it means an audit that names the gaps, not one that lists every possible option and leaves the firm to pick.
An audit that adds "nice to haves" creates its own risk. If a regulator later asks why you haven't implemented one, the audit is the reason you now have to answer for.
The plan you drew three MLROs ago may not fit the firm you have now
Most firms built their AML process at some point in the past, for the staff, software, and caseload they had then. The firm has moved on. The process often hasn't.
A proper time-and-motion study surfaces the bottlenecks. And when something's gone wrong, "human error" isn't a root cause, it's a category. The actual cause is almost always one of three things: lack of supervision, lack of time, or lack of expertise. Naming which one is what makes it fixable.
Policies should tell people what to do. Training should change what they do.
Policies don't need to restate the legislation. Most readers already know the regulatory context. What they need is the process: what to do, in what order, when to escalate, who to ask. A key facts front sheet covering the 20% of information that applies to 80% of cases beats expecting a busy fee earner to read 70 pages before opening a file.
Training that doesn't stick is worse than no training. It creates the appearance of coverage while behaviour stays the same. The training that works is targeted: built from file review findings, aimed at what specific people are actually getting wrong, and followed by a clear statement of what's expected. Asking someone to confirm they understand isn't box-ticking. It's the step most firms skip.
Get these three right and you've fixed Clarity, Communication, and Commitment. The other three, Capacity, Consistency, and Culture, are what the next post is about.
About First AML
First AML comes from the perspective of both a technology provider, but also as compliance professionals. Prior to releasing, First AML’s all-in-one AML workflow platform, we processed over 2,000,000 AML cases ourselves. Understanding the acute problem that faces firms these days as they try to scale their own AML, is in our DNA.
That's why First AML now powers thousands of compliance experts around the globe to reduce the time and cost burden of complex and international entity KYC. First AML stands out as a leading solution for organisations with complex or international onboarding needs. It provides streamlined collaboration and ensures uniformity in all AML practices.
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