Start with mindset and coordination
When the initial email or letter arrives, respond in a calm, controlled, and structured way. On day one, understand exactly what has been requested, the scope of the review, and the deadlines. Identify a central point of coordination — usually the MLRO or compliance lead — to manage the response and ensure consistency.
Know what's current
Document readiness is critical. The SRA looks not just at what documents say, but how well they are controlled and aligned. Be clear which documents are current, avoid circulating multiple drafts, and ensure anything submitted reflects the firm's approved position.
- Firm-wide risk assessment
- AML policies and procedures
- Training records
- A sample of files
Check for consistency
Your firm-wide risk assessment, policies, procedures, and training materials should all align. If they tell different stories, that can quickly raise concern. Common issues at this stage are inconsistency rather than major failings — policies that don't reflect practice, risk assessments that are too generic, and gaps in how CDD has been recorded.
Review before you submit
Carry out an internal review before submitting. Sense-check what the SRA is about to see, identify any gaps or inconsistencies, and check whether documents reflect actual practice. Files should be reviewed to ensure they clearly evidence the work done, especially around client due diligence and source of funds.
Manage deadlines and follow-ups
Deadlines are usually tight. Manage them actively, and if more time is genuinely needed, engage early to agree an extension rather than submit incomplete information. Treat file sampling and follow-up questions as an extension of the same process, and keep follow-up answers consistent with what you have already provided.
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.