What should an AML decision record explain?

Explain the path to the outcome

An AML decision record should connect evidence, assessment, outcome and reason. A status label alone cannot show how the decision was made.

For initial and ongoing CDD, section 111 expressly includes records of relevant analysis, risk assessment and decision making.

Source: Federal Register of Legislation: 111(2)-(3).

Separate facts and judgements

A practical note can identify the issue, evidence, assessment and action. Separate a customer’s explanation from a fact supported by independent evidence.

State the limits of the evidence. Do not turn uncertainty into an allegation.

Date later information separately. Preserve the original decision and the information available when it was made.

Source: Federal Register of Legislation: 111(2)-(3).

Invented example: activity with an explanation

In a fictional case, activity differs from the customer information on file. The reviewer obtains more evidence and decides on a response.

The record explains what prompted the review, what was considered and why the response followed.

Any unresolved question has a next action and a responsible person. This example does not determine whether a suspicious matter report is required.

Source: Federal Register of Legislation: 111(2)-(3).

Keep decisions usable and controlled

Use a controlled record location and link the supporting evidence. Restrict access to people who need the information for their work.

Retain the original decision and any later review result. Examine applicable disclosure restrictions before sharing the record.

A complete form can record an incorrect decision. The evidence and reasoning still need review.

Source: Federal Register of Legislation: 111(2)-(3).

Avoid retrospective certainty

A later reviewer may know facts that were unavailable at the time. Keep that distinction clear.

Assess the earlier reasoning against the information then available. Record how new evidence changes the next action.

Source: Federal Register of Legislation: 111(2)-(3).