Support During AML Supervisory Inspections
An inspection by the supervisory authority is no reason to worry – provided your anti-money laundering is documented, practised and traceable. We prepare you in a targeted way, provide expert support during the inspection and help you implement any requirements.
When do inspections take place?
Under Section 51 GwG, the competent supervisory authorities monitor whether obliged entities comply with their anti-money laundering obligations. Inspections may be triggered by specific events or carried out on a random basis – on site, in writing by requesting documents, or as a combination of both. In the gambling sector, there are additional checks by the gambling supervisory authority.
What inspectors typically want to see
Risk assessment
Up to date, company-specific, documented and approved by management (Section 5 GwG).
Internal safeguards
Work instructions, responsibilities, controls and their regular review (Section 6 GwG).
AML officer
Appointment, deputy, notification to the authority and verifiable activity (Section 7 GwG).
Due diligence obligations
Identifications, PEP checks, beneficial owners and records (Sections 10–17 GwG).
Training
Evidence of initial and ongoing instruction of all relevant employees.
Suspicious activity reporting
Internal reporting procedure, documentation of reviews and, where applicable, reports to the FIU (Section 43 GwG).
Our audit support services
- Pre-audit check: We review your documents through the eyes of the regulator and point out gaps before they become deficiencies.
- Structured audit file: Risk assessment, policies, evidence and records compiled clearly and completely.
- Preparing your staff: Short briefings so your team can answer typical questions with confidence.
- Support during the inspection: Expert communication with the authority, participation in meetings and answering follow-up questions.
- Follow-up: Action plan for findings, timely statements and implementation of requirements.
Typical findings – and how to avoid them
| Common deficiency | What helps |
|---|---|
| Risk assessment is outdated or a generic template | Annual update with concrete references to customers, products, locations and distribution channels |
| Work instructions exist but are not followed | Short, practical guidelines and documented spot checks |
| Training cannot be evidenced | Attendance lists or certificates for each employee and regular refreshers |
| Identifications incompletely documented | Clear thresholds, ID check with copy and mandatory details under Section 11 GwG |
| Red flags not documented | Simple internal reporting line to the AML officer and documented assessment |
How we work together
- Initial consultationClarify the reason, deadlines and scope of the announced inspection.
- Status reviewReview documents and prioritise action items.
- PreparationClose gaps, prepare the audit file, brief the team.
- Inspection & follow-upExpert support and implementation of any findings.
Inspection announced?
The sooner we start, the more room there is for preparation. Contact us – even at short notice.
Book a no-obligation initial consultationYour contact person
Alen Gruber
Certified Corporate Compliance Specialist
External AML Officer