Independent AML audit - What do you want from the process?

Insights / / Gibraltar


With legislative change in the air, many more firms in Gibraltar will find themselves looking at how they can comply with the requirement to have an independent anti-money laundering (AML) audit each year.

Some firms may have sufficient resources internally to be able to satisfy the requirement of ‘independence’, but it's likely that most firms won’t.  These firms will need to find a suitable firm or consultant, who has sufficient experience and knowledge in their sector to complete the audit process. In other cases, firms may want the comfort of having an independent review by a third party firm with additional sector experience.

Initial consideration of the matter probably goes straight to cost.

Insource or outsource?

Even if the process can be undertaken internally by staff sufficiently distanced from the day to day operations, there is a cost. Pulling experienced staff off income generating work and business development is not without its own cost (in particular as we all realign our businesses in the post Brexit and new COVID era). Using a professional service provider, therefore offers the benefit of undertaking the work with clearly defined objectives, scope and project management.

Secondly, what should you expect from your AML audit?  To fulfil a regulatory requirement or also to get expert advice on ways to improve your AML framework to not only conform with legislation but also ‘best practice’?

There are many considerations that need to be taken into account when choosing a firm or consultant to complete your AML audit. Such as do they have a suitable Professional Indemnity (PI) cover that you can rely on, what are the costs, what relevant experience do they have and who else will want to view your audit report?

What should you expect from your AML audit?

Having an auditor that is experienced in carrying out AML audits in your sector will mean a less disruptive and intrusive experience for you and more detailed and practical findings, that you can use to improve your AML framework.  An experienced auditor should highlight areas where improvement could be made, as well as areas that are deficient. 

At Ince, we have experience in completing AML audits in many sectors, including Gaming, Blockchain, Financial Services and Real Estate. Our team of compliance professionals, lawyers and project managers will conduct a seamless and organised audit and provide a detailed report for you to use as guidance, as well as provide to your Regulator and other counterparties.  We can recommend areas of improvement, improve efficiencies and also potentially reduce costs (by providing tool analysis and recommendations for appropriate third party RegTech solutions).

Kriya Patel, CEO Transact Payments Limited, said:

“As a regulated company the need to ensure that our AML practices, processes and controls are effective are paramount. We selected Ince to conduct an independent audit given their enhanced knowledge of our payment services business model and their ability to conduct an audit that is built on a foundation of strong understanding of what we do – with a team that has in-depth practical experience of operating within an e-money and payments environment first hand.”
Heather Adamson

Heather Adamson Head of Fiduciary

Related services:


Anti-Money Laundering (AML)