1. Core documents, current and approved
An inspection — like a desk-based review — starts with a document request, often on a 10–14 day timeframe. The material needs to be accessible, current, and clearly the firm's approved position. Avoid circulating multiple drafts: be clear which version is the live one.
- Firm-wide risk assessment, specific to your clients, services, jurisdictions, and delivery methods
- AML policies, controls, and procedures in their approved, current versions
- Training records showing ongoing and role-specific AML training
- A sample of files demonstrating CDD and source-of-funds work
2. Consistency across the framework
The SRA tests whether your documents agree with each other and with practice. Inconsistency — not catastrophe — is the most common issue. Sense-check that your firm-wide risk assessment, policies, procedures, training materials, and client files tell one story.
If your risk assessment describes one approach and your files show another, that gap will be noticed. Reglo keeps these aligned so they don't drift apart between reviews.
3. People who can explain the framework
Inspections are interactive. The SRA may interview the MLRO, senior management, and fee earners to test how well AML processes are understood and applied. The MLRO in particular should be able to explain clearly how the firm identifies, assesses, and mitigates AML risk.
Brief everyone who may speak to the SRA from one current source of truth. The aim is not perfect or overly technical answers — it is credible, accurate, and consistent ones.
4. Files that evidence the work
File sampling tests how controls operate in real matters. Before submission, review sampled files to ensure they clearly evidence the work done — particularly around client due diligence and source of funds. Where a matter was, or wasn't, escalated to the MLRO, the reasoning should be recorded.
5. An internal review before you submit
Run an internal review before anything goes to the SRA. Step back, sense-check what they are about to see, and identify gaps or inconsistencies. This stage is often where issues can be found and fixed early — before they become regulatory findings.
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.