AML compliance self-assessment checklist

This checklist covers the core elements that regulators expect to see in an AML compliance programme for non-financial institutions. However, it is a self-assessment tool and does not constitute legal advice. Your specific obligations depend on your jurisdiction, regulatory supervisor, and the nature of your business. We recommend using this checklist as a starting point and consulting with a compliance professional for tailored guidance.

At minimum annually, and whenever there are material changes to your business model, customer base, regulatory environment, or risk profile. Many supervisory bodies recommend more frequent reviews for higher-risk businesses.

All items in this checklist represent regulatory expectations or best practices. A fully compliant programme should aim for 100%. Any unchecked items represent potential gaps that should be addressed. Items in the Sanctions Screening and CDD sections are particularly critical, as failures in these areas attract the most regulatory scrutiny.