COMPLETIONmonitor and AML: From Digital Checks to Evidenced Decisions

Originally published July 2014. Updated 29 October 2026.

An electronic identity check has been completed. The AML question on the checklist has been answered. The matter is approaching exchange.

Can another person reviewing the file establish what was checked, what concerns arose and why the firm decided to proceed?

That is an important test of a digital AML process. Software can help organise checks, flag concerns and make outstanding work visible. The firm still needs to assess the evidence and record the decisions those checks support.

What can COMPLETIONmonitor support?

COMPLETIONmonitor provides pre- and post-completion checklists, alerts and management oversight for conveyancing practices.

Its published CQS functionality describes capabilities for embedding a firm’s AML procedures into the workflow, requiring fee earners to confirm that protocols have been followed. It also describes configurable risk alerts for relevant managers.

Firms should establish which features are included in their subscription, which require configuration and how those features correspond with their approved procedures.

Do not describe a safeguard as operational until it has been configured and tested. If the policy requires a particular approval, staff need to know how that approval is obtained, recorded and communicated within the systems they actually use.

An electronic result answers a defined question

An identity-verification result should be understood in the context of the service purchased and the checks it performs.

It does not, by itself, establish that the funding explanation is supported, the beneficial ownership has been understood or the client and matter risk assessment is adequate.

Staff should know:

• What the result establishes and what falls outside its scope.
• Who reviews alerts, discrepancies and incomplete results.
• What further information may be needed.
• Who can approve the next step under the firm’s procedures.
• Where the evidence and reasoning are retained.

A result described as a pass should not close an unrelated enquiry. Equally, a referral result needs investigation rather than an automatic assumption that the client cannot be accepted.

Connect the checklist answer to the evidence

A checklist entry stating “source of funds checked” leaves an important question unanswered: what work supports that conclusion?

The underlying record should enable an appropriate reviewer to find the client’s explanation, relevant evidence, investigation of material inconsistencies and the reasoned outcome.

Records may sit in different systems. What matters is that the firm knows where they are, can retrieve them and can connect them to the decision recorded on the matter.

Our guide to testing source of funds during internal AML file reviews considers how to examine the quality of the investigation rather than simply count documents.

Changed funding should prompt a fresh decision

Consider an illustrative purchase. The buyer initially proposes to contribute personal savings. Later, part of the contribution is expected from a company connected with a relative.

The original identity check may remain relevant, but it does not resolve the changed funding arrangement.

The fee earner should identify the change, assess its significance, obtain appropriate information and reconsider the matter risk assessment. Any approval required by the firm’s procedures should address the arrangement now proposed.

The example does not establish suspicious activity. It illustrates why a completed onboarding stage should not prevent relevant later information reaching the person responsible for assessing it.

Our article on what happens after a CMRA identifies higher risk explains how the assessment should connect with enquiries, mitigation, approval and monitoring.

Make escalation and approval responsibilities clear

A useful alert reaches someone who understands what decision is required and has authority to make it.

Check the recipient, absence cover and procedure for recording the response. Where approval is conditional, identify who checks that the conditions have been satisfied.

Distinguish the responsibilities of the fee earner, supervisor and relevant compliance officer. The MLRO, MLCO, COLP and COFA should not be treated as interchangeable titles.

The firm should also distinguish an internal workflow approval from any separate legal restriction or reporting requirement. A system status cannot authorise conduct that the law prohibits.

Use the SRA’s guidance to review implementation

The SRA’s guidance on AML policies, controls and procedures, published on 22 October 2026, emphasises the connection between documented requirements and everyday work.

Its distinction between policies, controls and procedures is useful when reviewing software. The policy establishes the approach, the controls help manage risk and the procedures explain what staff must do.

A practical review can ask:

• Does the system reflect the current procedure?
• Can staff explain what an AML question requires them to assess?
• Are outstanding concerns visible to the appropriate reviewer?
• Can the file demonstrate when decisions were made?
• Do policy amendments require changes to forms, settings or training?

Our guide to tailoring AML policies for conveyancing work develops these questions through practical examples.

Test the answers recorded in the system

Management information can help identify matters requiring attention. It also needs testing against the underlying file.

Select matters with different characteristics, including files with few recorded concerns. Examine whether the answers are supported and whether relevant changes were recognised.

A file with no alerts may be straightforward. It may also contain inaccurate inputs or an issue the workflow did not capture. The review should establish which explanation applies.

Where a gap is identified, record the action, responsible person and follow-up. Consider whether the weakness concerns the procedure, configuration, staff understanding or the quality of the investigation.

Independent audit provides a separate examination

Routine supervision and digital oversight support the firm’s ongoing controls. An independent AML audit can examine their design and effectiveness alongside policies, risk assessments, client files and staff understanding.

Software-generated records are evidence for that examination. They should be considered with the underlying material rather than treated as an independent audit in themselves.

Regulation 21 requires an independent audit function where appropriate to the size and nature of the business. It does not require every firm to purchase an annual external audit.

The practical objective is to identify where the firm’s records and procedures support sound decisions, where they fall short and what needs to change.

This article concerns conveyancing practices in England and Wales undertaking work within the Money Laundering Regulations. Product features depend on the services and configuration agreed with the firm. Confirm current functionality before relying on a particular control.