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The Payment Practice
The Payment Practice
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    • Home
    • About Us
      • About Us
      • Newsletters and Blogs
    • FCA Applications
      • FCA Licence Applications
      • Variation of Permissions
      • Change In Control
      • Exclusions
    • Safeguarding
      • Safeguarding Audit
      • Safeguarding Accounts
    • AML Audits
    • PSR & EMR Compliance
    • Ongoing Support
    • Agent & PF Oversight
    • FCA Remediation Support
    • Business Lending Support
    • Contact Us
  • Home
  • About Us
    • About Us
    • Newsletters and Blogs
  • FCA Applications
    • FCA Licence Applications
    • Variation of Permissions
    • Change In Control
    • Exclusions
  • Safeguarding
    • Safeguarding Audit
    • Safeguarding Accounts
  • AML Audits
  • PSR & EMR Compliance
  • Ongoing Support
  • Agent & PF Oversight
  • FCA Remediation Support
  • Business Lending Support
  • Contact Us

AML Audits

We deliver AML and financial crime audits that are structured, practical, and designed to avoid surprises.

Our approach is simple:


Identify the issues first, fix them properly, then complete the formal audit.


This ensures firms remain in control of the process and are not exposed to unexpected findings at the final stage.

Our approach

We do not conduct audits as a one-off “pass/fail” exercise.


Instead, we follow a structured three-stage process:


1. Gap Analysis

We conduct a detailed review of your AML / financial crime framework. Our assessment is aligned to UK regulatory expectations and covers all key areas of AML compliance. 


2. Report and Remediation

Following the gap analysis, we provide a detailed  report setting out:

  • Areas of compliance
  • Identified gaps and weaknesses
  • Clear, practical recommendations for remediation


You then have the flexibility to complete remediation work at your own pace, either internally or with our support.


This stage is critical — it ensures that issues are addressed before the formal audit is finalised.


3. Final Audit Report

Once remediation is complete, we perform a final review and issue the formal AML audit report.

Because gaps have already been identified and addressed, the final report reflects the firm’s actual compliant position, not a list of avoidable failings.


This approach ensures:

  • No unexpected findings at final audit stage
  • A clean and defensible audit outcome
  • Full transparency throughout the process

Scope of audits

We offer two levels of financial crime audit, depending on your requirements:

AML / CTF Audit

A focused review of AML compliance, covering all requirements under AML legislation and regulation. This includes full coverage of areas such as 

  • Governance, MLRO and accountability
  • Business-Wide Risk Assessment (BWRA)
  • Policies, controls and procedures
  • Customer due diligence (CDD / EDD)
  • Sanctions, PEPs and screening
  • Transaction monitoring
  • SAR processes and reporting
  • Training and record keeping

Financial Crime Audit (FCP)

A broader audit covering the full financial crime framework, including:

  • AML / CTF (as described above)
  • Fraud prevention
  • Anti-bribery and corruption


This provides a more holistic view of financial crime risk and control effectiveness across the business. 

Remediation support

Where required, we provide hands-on support to implement remediation actions, including:

  • Updating AML frameworks and policies
  • Strengthening BWRA and risk methodologies
  • Redesigning CDD / EDD processes
  • Improving transaction monitoring and screening controls
  • Enhancing governance, oversight and MI

Why our approach works

Traditional audits often identify issues at the end of the process, leaving firms with findings but no time to resolve them.

Our approach reverses that.

  • Issues are identified early
  • Remediation is completed before final reporting
  • The firm retains control throughout
  • The final audit reflects reality, not theory

Get in touch to arrange an AML Audit

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The Payment Practice

Hours

Mon

09:00 – 17:00

Tue

09:00 – 17:00

Wed

09:00 – 17:00

Thu

09:00 – 17:00

Fri

09:00 – 17:00

Sat

Closed

Sun

Closed

Anti Money Laundering Support

Digital illustration representing AML support with financial security icons.

Anti-money laundering (AML) is a central regulatory concern for payment and e-money firms. Given the speed of transactions, the volume of funds, cross-border activity, and reliance on technology and third parties, the payments sector is particularly exposed to money laundering, fraud, sanctions breaches, and other forms of financial crime. To address these risks, AML compliance has become one of the key priority areas for the Financial Conduct Authority (FCA). The FCA expects firms to establish clear, proportionate, and effective AML frameworks that are embedded into day-to-day operations, rather than treating them as merely a box-ticking exercise. This encompasses strong governance and oversight, a robust firm-wide risk assessment, effective customer due diligence, transaction monitoring, sanctions screening, and timely reporting of suspicious activity. For payment firms, weaknesses in AML processes are often a common driver of regulatory intervention, supervisory action, and enforcement. The FCA will evaluate not only the existence of appropriate policies but also their proper implementation, understanding by staff, and effectiveness in practice. Firms are expected to actively identify, manage, and review AML risks as their business evolves, which may involve utilizing AML audit services to ensure ongoing compliance and effectiveness.

Our comprehensive AML Services

AML Gap Analysis


We review your existing AML framework against current supervisory expectations for your sector, identifying gaps, weaknesses, and areas of regulatory risk. This comprehensive analysis is a key component of our AML audit services, ensuring you are aligned with best practices in AML compliance.


You receive a clear, practical report with prioritized remediation actions.


AML Audits & Independent Reviews


Our AML audit services include thorough AML audits and independent reviews designed to assess both design and operational effectiveness, tailored to your business model and regulatory context. The outputs of these reviews are suitable for internal governance, supervisory engagement, or third-party assurance.


Annual AML Compliance Attestation


We support firms with annual attestations of AML compliance, helping to evidence that:


- Controls remain appropriate and effective

- Risk assessments have been reviewed and updated

- Policies and procedures remain current

- Training obligations have been met


This creates a clear annual compliance record, reinforcing your commitment to anti-money laundering practices.


Policies, Procedures & Template Access


We develop bespoke AML policies and procedures tailored to your sector and risk profile. Where appropriate, firms also receive access to templated AML documents, enabling efficient updates as regulatory expectations evolve.


AML Training


We deliver practical, role-specific AML training tailored to your sector, covering:


- Relevant money laundering typologies

- CDD and EDD expectations

- Ongoing monitoring and escalation

- SAR decision-making and AML governance


Our training is fully documented and suitable for supervisory review, ensuring that your team is well-equipped to meet anti-money laundering obligations.


Our approach


We support regulated firms in a way that is:


- Risk-based and proportionate

- Aligned to sector-specific supervisory expectations

- Focused on evidence and real-world implementation

- Practical, clear, and regulator-ready


No one-size-fits-all compliance.

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The Payment Practice

Copyright © 2026 The Payment Practice - All Rights Reserved.

The Payment Practice is a trading name of The Cambridge Practice Ltd.
Registered in England and Wales. Company number 12732644.
Registered office: Compass House, Chivers Way, Histon, Cambridge, England, CB24 9AD.

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