Keep the case understandable.
AMLCode is designed to bring the customer’s details, the people checked and their results into one report, with supporting evidence for your firm’s review.
Keep the reasoning close to the result.
AMLCode is designed to bring screening results and supporting evidence into one report, making it easier for colleagues to review the case.
Your client file should also explain how a potential match or inconsistent detail was resolved. Where further evidence is needed, record the open question and the person responsible for following it up.
The report belongs within your AML records.
HMRC expects firms to keep evidence of their due diligence measures. The report supports that record; it does not replace your firm’s risk assessment, policies or decision record.
Agree how reports will be received, stored, accessed and retained within your own process. A report generated at onboarding is not a promise that its information will remain current.
HMRC: your AML responsibilitiesIs the report a certificate of AML compliance?
No. It is evidence of the checks in the case. Your firm remains responsible for deciding whether its due diligence is sufficient and for its wider AML obligations.