What an AML Investigation Should Leave Behind for the Regulator
AML Decision Evidence in the UK and Europe: What a Closed Case Should Show When a case closes, what stays behind? For many firms the honest answer is a status flag, a few notes and an analyst's memory. That is enough until someone senior, internal or external, asks how a particular decision was reached. In short: a closed AML case should let a stranger see what triggered it, what was examined, what was found, why the outcome follows and who approved it. Anything less tests someone's memory instead of recording a decision. The five things a reviewer looks for Element The question it answers Trigger Why was this case opened? Evidence examined What did the investigator look at, and what was unavailable? Findings What was material, and what was set aside? Rationale Why does the outcome follow from the findings? Approval Who agreed, and at what level? The level of detail should match the risk. A routine closure needs less than a network of linked transact...