Field notes · 8 January 2026
Preparing compliance teams for AML walkthroughs
Walkthroughs fail less on policy wording and more on whether staff can narrate the last alert they closed.
An AML walkthrough is a conversation, not a document dump. The reviewer asks a case officer to open a recent alert, explain why it fired, show the investigation notes, and describe the escalation decision. If that person hesitates, the finding writes itself.
Rehearse with real, anonymised cases from the last quarter. Include one alert that was closed as a false positive and one that escalated. Officers should be able to point to the exact fields they checked and the time stamps on each action.
Keep thresholds and typology notes version-controlled. Reviewers notice when the rule set on screen differs from the policy dated last year. A short change log bridges that gap without rewriting the entire manual.
Escalate ownership should be visible. If the MLRO-equivalent role is vacant or covered by a founder, say so and document interim arrangements. Ambiguity here is treated as a governance weakness, not a staffing footnote.
After the walkthrough, capture follow-ups in a dated action list. Returning reviewers remember unfinished items more clearly than polished slides.