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Audit trails7 min read

How to build an AML audit trail before the SRA asks

Weak audit trails are one of the most common AML issues — including limited evidence of rationale, source-of-funds analysis, and decision-making on files. The SRA is often more concerned by systemic compliance failures and poor governance than by a single isolated breach.

An audit trail built as work happens is far stronger than one assembled under deadline. Here's how to approach it.

Capture as work happens

Record policy changes, approvals, training, and attestations the moment they occur. Evidence captured continuously is accurate and complete; evidence reconstructed before a review has gaps and inconsistencies.

Record the rationale, not just the outcome

On client matter risk assessments, the common issue is boxes ticked with no explanation. The key is to be able to justify what the assessment says. If a matter isn't escalated to the MLRO, record the reasoning; if it is, record why it is high risk and why it is being escalated.

Link the trail together

Connect each policy version to its source, its approval, the staff who acknowledged it, and the training that backs it. A linked trail lets you show the whole chain — from regulatory change to staff understanding — rather than disconnected records.

Make it exportable

When the SRA, an insurer, or a panel asks, you should be able to export a complete, coherent pack in hours rather than days. Continuous capture makes production an export, not a project.

Reglo helps firms keep this evidence organised and audit-ready — humans approve every change. AI drafts and organises; your compliance team decides.

This guide is general information for compliance teams, not legal or regulatory advice. Always refer to the SRA's current guidance and take your own professional advice where needed.

Common questions

What makes an audit trail weak in the SRA's eyes?

Limited evidence of rationale, source-of-funds analysis, and decision-making — and disconnected records that don't reconcile. Systemic gaps concern the SRA more than a single breach.

See how Reglo keeps this evidence ready

Book a demo and we'll show you how Reglo keeps your policies, training, attestations, and audit-ready evidence aligned for SRA reviews — with humans approving every change.

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