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How to prepare for your AML/CTF audit using Workflow

This article explains the steps involved when preparing for an AML/CTF audit =

How to prepare for your AML/CTF audit using Workflow

When it's time for your AML/CTF audit, give the auditor a login to Workflow — that's where all your records are, and it's the most efficient way for them to review your compliance history.

Step 1: Create a login for your auditor

  1. Go to Settings and click Team

  2. Click Invite User

  3. Enter your auditor's email address

  4. Assign them an Agent plan — this lets them view cases and records.

There is no additional charge for user seats. You can give your auditor access without affecting your billing.

Step 2: Brief your auditor on how to navigate Workflow

When your auditor logs in, show them (or send them this article):

  • Cases — the main list of all AML cases, filterable by status, risk level, and date range

  • Risk Assessment tab within each case — shows the completed assessment and result

  • Documents tab within each case — shows all uploaded source of funds and other compliance documents

  • History tab within each case — shows the full audit trail of every action taken on the case, timestamped and attributed to specific users

Step 3: Use Workflow's built-in filters, not manual exports

  1. In the Cases view, use the filters to narrow by risk level, date range, or status

  2. Select the Case requiring a review to see all the related details

Auditors typically work through high-risk cases first, then medium-risk. The filter by risk level makes this straightforward.

What auditors typically look at

High-risk cases receive the most scrutiny. For each one, auditors will check:

  • Was verification completed before the service was provided?

  • Was a risk assessment completed, with an appropriate result?

  • Is source of funds (and source of wealth, if applicable) documentation on file?

  • Are there notes explaining any flags, overrides, or judgement calls?

Medium-risk cases follow a similar review pattern, with particular attention to source of funds documentation.

Low-risk cases are generally reviewed at a higher level — auditors confirm the checks were done and the assessment was completed.

How review periods support your audit

Workflow's review period system helps auditors understand your ongoing obligations:

Risk level

Review period

What this means for audit

Low risk

3 years

Client re-verified every 3 years — auditor checks that no client has gone without a check for longer than this

Medium risk

2 years

More frequent re-verification — auditor checks for any lapsed medium-risk clients

High risk

1 year

As above — and with closer attention to enhanced due diligence documentation

Workflow displays the review period status for each client, making it easy to identify any that are approaching or past their review date.

What if you discover a gap during audit preparation?

If you find a case where a check wasn't done, documentation is missing, or a risk assessment was skipped:

  1. Do not try to backdate or reconstruct records

  2. Create a note in the case acknowledging the gap and explaining the circumstances

  3. Complete any missing steps now (e.g., run a late verification if the client is still available)

  4. If a check genuinely cannot be completed retrospectively, document why

Auditors are experienced with gaps in new compliance programs — particularly in the early years of Tranche 2. Transparency and documentation of your response is more valuable than attempting to cover the gap.

What if my auditor has questions about how Workflow works?

Direct them to this Help Centre, or contact APLYiD support — we can assist auditors with questions about how records are stored and how the system generates its outputs.

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This article provides general information only and is not legal advice.

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