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What HMRC Will Look for in an AML Inspection

When HMRC carries out an AML inspection, it’s not just checking boxes — it’s testing whether your firm’s controls genuinely work. Being prepared can make the difference between a smooth visit and one that leads to follow-up actions or penalties. Here’s what inspectors will focus on and how you can stay ready.

Key areas of focus during an HMRC inspection

  • Firm-wide risk assessment - Inspectors will want to see a risk assessment that:

    • Reflects the current risks your business faces

    • Is tailored to your clients, services, and delivery channels

    • Has been reviewed and updated regularly

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  • Policies and procedures that match your risks - Your AML policies should:

    • Clearly explain how you apply CDD, EDD, record-keeping, and reporting

    • Be consistent with your risk assessment

    • Be understood and followed by your team

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  • Customer due diligence files - HMRC will sample your CDD records to check:

    • ID and verification documents

    • Evidence of beneficial ownership checks

    • Source of funds enquiries where relevant

    • Dates, responsible staff, and decision-making notes

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  • Staff training records - Inspectors will expect proof that:

    • Training is tailored and relevant

    • Staff know how to spot suspicious activity

    • Refresher training takes place at appropriate intervals

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  • Ongoing monitoring and internal reviews - They will want to see how you:

    • Monitor client relationships for changes in risk

    • Review files internally

    • Address issues you identify

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Common findings in inspections

❌ Risk assessments that are generic or outdated
❌ Policies that aren’t put into practice
❌ Missing or incomplete CDD records
❌ Weak or no evidence of source of funds checks
❌ No records of training or internal file reviews

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How to prepare for an inspection

  • Carry out your own file reviews regularly. Spot gaps before HMRC does.

  • Keep records organised and accessible. This makes inspections faster and smoother.

  • Engage your team. Everyone should understand their AML role.

  • Test your controls. Make sure what’s on paper is happening in practice.

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Final thought

An HMRC inspection is your chance to show that your firm takes AML seriously. With the right preparation, you can demonstrate a culture of compliance and avoid unnecessary risks.

 

If you'd like support in getting ready, Reguloop offers mock inspections, file reviews, and policy refreshes designed to help you pass with confidence.

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