A failed or flagged AML result does not automatically mean you cannot proceed — it means you need to review the result, record your decision, and either resolve the issue or escalate if needed.
Understanding the result types
FAIL: One or more checks did not pass — this could be an identity mismatch, a PEP flag, an address verification failure, or a watchlist match.
REVIEW: The check needs a human decision. Workflow has flagged something that requires your assessment before you can proceed.
PASS: All checks passed. No further action required on the AML result.
Step-by-step: what to do after a FAIL or REVIEW
Open the case and click into the failed check to see which specific component failed (identity, address, PEP screening, watchlist).
Review the detail. Determine whether the failure is a genuine concern or a false positive.
Decide whether to proceed, request more information from the client, or decline to act.
Record your decision in the Provide reason field. Be specific — write what you reviewed, why you concluded what you did, and what action you are taking.
Click Approve or Decline to finalise the case status.
What to write in the decision field
Your decision note forms part of the audit trail. Examples:
PEP flag, not a match: "PEP match reviewed — flagged individual is [name], a former politician in [country]. Client confirmed as different person of same name. Supporting ID sighted. Proceeding."
Address fail, identity passed: "Client's address did not verify electronically. Client provided recent utility bill confirming current address. Manual verification complete. Proceeding."
All checks passed: "All identity and AML checks passed. Risk assessed as low. No adverse findings. Approved to proceed."
When to escalate
Do not proceed if:
A watchlist or sanctions match appears that you cannot clearly rule out as a false positive.
The client cannot or will not provide identity documents.
You have a genuine suspicion of money laundering or fraud.
In these cases, do not tip off the client. Contact your compliance officer or seek legal advice. You may have a reporting obligation to AUSTRAC.
This article provides general guidance only and is not legal advice.
Related articles
Understanding biometric check results (pass, fail, review, error)
What is a PEP flag and what do I do if my client gets one?
Understanding the case history and audit trail