PAMLP (a proactive AML/sanctions assessment of mid-tier firms) is one of a number of supervisory assessments being utilised by the FCA, but one that many firms are falling foul of. Firms typically receive 4-6 weeks’ notice of a visit, so if you receive a notification it’s probably too late to be on the front foot. And that’s why firms who get the best outcomes tend to have been proactive themselves. The most material findings by the FCA often arise when firms have not self-identified their own issues.

Can you be truly independent when assessing your own firm? If not, you may benefit from Avyse Partners’ mock PAMLP assessment, which is designed to mimic an FCA assessment. But it is not just a question of identifying whether you have any issues, it is also how well you communicate these gaps. So, we also assess how good you are at “telling the story”: What do you do, where is your risk and how good are you at managing it?