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Record-Keeping and Documentation for AML

In AML compliance, if it is not on the file, regulators will assume it did not happen. This course shows lawyers, supervisors and support teams how to create clear, complete AML records that demonstrate sound judgement—not just a stack of documents. Through a Horizon Engineering case study, learners see how seemingly small gaps in documentation can create real regulatory risk even where the client is entirely legitimate.

Online, self-paced learning

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Identifies and addresses knowledge gaps

Measures actual competence, not just activity

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Course Overview

In AML compliance, if it is not on the file, regulators will assume it did not happen. This course shows lawyers, supervisors and support teams how to create clear, complete AML records that demonstrate sound judgement—not just a stack of documents. Through a Horizon Engineering case study, learners see how seemingly small gaps in documentation can create real regulatory risk even where the client is entirely legitimate.

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Who Should Take This Course

Fee earners in all practice areas who complete CDD, risk assessments and escalations

Onboarding and admin staff who collect and store ID, ownership and screening records

Supervisors, partners and MLROs responsible for AML oversight and file quality

Operations and risk teams designing file structures, retention and audit processes

What You'll Learn

  • Why AML records matter: how regulators, law enforcement and auditors use files to assess compliance
  • A case study on Horizon Engineering, where missing documents and thin risk notes lead to criticism despite a genuine client
  • The three core questions every AML record must answer: who the client is, what checks and assessments were done, and why the firm proceeded or declined
  • Required client identification and verification records, including identity evidence, beneficial ownership and document quality standards
  • How to document risk assessment and CDD/EDD steps, including short written reasoning rather than labels alone
  • Recording screening and monitoring: sanctions/PEP results, periodic reviews, and changes in structures, jurisdictions or payment routes
  • How to capture decisions, escalations and outcomes, including compliance advice, conditions, and any SAR-related steps
  • What counts as “business correspondence” for AML purposes and what does not
  • Legal retention requirements for AML files, how they interact with data protection rules, and what this means for archiving and destruction
  • Practical habits for strong records: contemporaneous, specific notes; consistent storage and naming; and showing the reasoning, not just the result
  • The distinct roles of onboarding/admin, fee earners and supervisors in producing a coherent AML story on file

Key Learning Outcomes

By the end of this course, you will be able to:

  1. Explain why good AML record-keeping protects the firm, individual lawyers and clients.
  1. Identify the essential documents and data that must be on every AML file, and check their quality and currency.
  1. Record client and matter risk assessments with clear, concise reasoning rather than bare “Low/Medium/High” labels.
  1. Document screening, monitoring and escalations in a way that an external reviewer can follow.
  1. Apply statutory retention periods correctly and understand when records must be kept, archived or destroyed.
  1. Use simple best-practice techniques to keep AML records organised, searchable and audit-ready.‍
  2. Review a file and judge whether it tells a coherent “who, what, why” AML story that would satisfy a regulator or internal audit.

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Why This Course Matters

Weak documentation is one of the most common findings in AML inspections—and it is entirely within a firm’s control. This course helps your teams move beyond “we know this client well” to a disciplined approach where key AML decisions are properly evidenced. With better records, your firm can demonstrate compliance quickly, reduce remediation costs, and give partners confidence that their files would stand up to external scrutiny.

Global Clients:

Please email for buying assistance: hello@denkenknowledge.com

What people say

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Frequently asked questions

Have a look at most frequently asked questions.

Is there a minimum or maximum team or class size?

Denken is designed to support teams or classes of any size, whether you’re a small firm or a large organisation. There’s no minimum or maximum: we adapt to your needs.

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Yes, you can pay for our courses and series of modules via Invoice. Please use the Contact form to make an enquiry, and we will email over an invoice when you're ready. Please note, we do not accept purchase orders as a payment method.

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Yes, we use Stripe for online credit card payments. Details will be visible on your invoice.

Is there Client and Learner support available?

Yes, we are here to help every step of the way, both as a client and a learner using our platform.

How do I access course materials?

Course materials can be accessed through our platform dashboard once you or your learners have been enrolled. Each learner will receive a Welcome Email with full instructions.

Can I get a refund for a course?

You may cancel your course booking at any time before payment has been made by emailing us at hello@denkenknowledge.com. Once you have accessed your course on our platform no refunds will be made.

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