AML Judgment Gap Report · Full findings
Accountancy, Tax and Insolvency
This is a specimen. The cases, the weights, the methods and the sources are real, and are what your team would sit and what your own report would cite. The scores are invented, for a hypothetical cohort of 14 people. A real report carries your own results and nothing else.
Your team detects 7 of the 21 money laundering methods that apply to this sector. 5 need action, and 3 of those are rarely covered by standard training.
3 of these are urgent. Your team was tested on them and missed them.
Your assessment is 14 cases, not one. Each covers a different part of your exposure, and the appendix shows how many of your 21 methods each one carries. Measured against the methods that apply to this sector, not against other firms.
Since the last sitting
September cohort against March cohort. Your team detected 9 methods then and 7 now. 6 went backwards.
What to do
For each one, ask a single question. Does the team not know the method, or do they know it and have no rule that would surface it? The first needs a briefing. The second is a control gap, and it is the more serious answer.
- High
- Tested and missed, on a case covering a large part of your exposure.
- Medium
- Tested and missed on a smaller case, or never tested on one that matters.
- Low
- Never tested, and a small part of your exposure.
Ordered by priority. The reason for each is printed with it, so you can disagree with the ranking.
- 01
Accounts Prepared to Legitimise Falsified Records
HighYour team was tested on this and missed it. It sits in The Client Engagement, which covers 8 of the 21 methods that apply to you. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Client Engagement — covers 8 of your 21 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Filed accounts showing turnover a business of that size, premises or headcount could not generate; certificates of confirmation supporting figures no independent record corroborates; and a cash-intensive client whose declared takings rise without any matching change in the operation.
90 days · Re-testSit The Client Engagement again, on the version the team has not seen.
OwnerTarget date - 02
Insolvency as a Laundering Endpoint
HighYour team was tested on this and missed it. It sits in The Client Engagement, which covers 8 of the 21 methods that apply to you. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Client Engagement — covers 8 of your 21 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Assets and trade transferred to a newly incorporated company with the same operation and different directors shortly before insolvency; directors with a history of successive failed companies in the same trade; and a company whose final months show payments to connected parties rather than to creditors.
90 days · Re-testSit The Client Engagement again, on the version the team has not seen.
OwnerTarget date - 03
Mini-Umbrella Company Fraud
HighYour team was tested on this and missed it. It sits in The Client Engagement, which covers 8 of the 21 methods that apply to you. Training rarely covers this, so a refresher will not fix it.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Client Engagement — covers 8 of your 21 methods
- Training
- Rarely covered by standard annual refreshers
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Large numbers of newly incorporated companies sharing directors, addresses or formation agents, each running modest payroll, appearing and dissolving on a cycle.
90 days · Re-testSit The Client Engagement again, on the version the team has not seen.
OwnerTarget date - 04
Investment Migration and Residence Schemes
MediumYour team was tested on this and missed it.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 2 of your 21 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Source of wealth evidenced principally by the qualifying investment itself, onboarding shortly after grant of status, and jurisdiction of residence inconsistent with any economic or family connection.
90 days · Re-testSit The Private Client File again, on the version the team has not seen.
OwnerTarget date - 05
MTIC and VAT Carousel Fraud
MediumYour team was tested on this and missed it.
- Result
- Caught 42% of the laundering customer's alerts.
- Tested by
- The Goods Chain — covers 1 of your 21 methods
Now · BriefSend the team the register entry. It has the mechanism, the signal and the sources.
30 days · ControlWhich rule, report or alert would surface this?
Rapid high-value trading between newly incorporated counterparties in the same goods, payments that pass through in hours, margins too thin to support the businesses, and directors with no trading history in the sector.
90 days · Re-testSit The Goods Chain again, on the version the team has not seen.
OwnerTarget date
On your own report
Each line carries your team’s result, an owner and a date. The re-test at 90 days shows what has moved.
Appendix
Evidence
Everything the finding above rests on, for anyone who wants to check it.
By case
The 14 cases that make up your assessment. Detection rate is the share of the laundering customer’s alerts the team caught. The last column counts people who escalated everything, which catches the laundering customer without deciding anything and scores badly for that reason.
| Case | Your methods | Share of assessment | Runs | Median mark | Detection rate | Escalated everything |
|---|---|---|---|---|---|---|
| The Client Engagement | 8 | 19% | 14 | 49 | 46% | 3 of 14 |
| The Relationship Review | 6 | 17% | 14 | 87 | 83% | 3 of 14 |
| The Client Account | 5 | 14% | 14 | 80 | 77% | 3 of 14 |
| The Policy Book | 4 | 11% | 14 | 87 | 83% | 3 of 14 |
| The Invoice Pack | 2 | 6% | 14 | 37 | — | — |
| The Onboarding Interview | 2 | 6% | 14 | 87 | — | — |
| The Private Client File | 2 | 6% | 14 | 48 | 45% | 4 of 14 |
| The Alert Queue | 1 | 3% | 14 | 82 | 79% | 3 of 14 |
| The Fundraising Appeal | 1 | 3% | 14 | 65 | 63% | 3 of 14 |
| The Disclosure | 1 | 3% | 14 | 85 | — | — |
| The Goods Chain | 1 | 3% | 14 | 45 | 42% | 2 of 14 |
| The Incoming Payment | 1 | 3% | 14 | 69 | 65% | 3 of 14 |
| The Securities Book | 1 | 3% | 14 | 53 | 50% | 3 of 14 |
| The Sponsorship File | 1 | 3% | 14 | 42 | 39% | 3 of 14 |
Every method
All 21 methods that apply to this sector, and where each one is documented. Full citations are at amlbenchmark.com/coverage.
| Method | Case | Rate | Result |
|---|---|---|---|
| Accounts Prepared to Legitimise Falsified Recordsrarely trainedHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraph… | The Client Engagement | 46% | Missed |
| Insolvency as a Laundering Endpointrarely trainedHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraph… | The Client Engagement | 46% | Missed |
| Mini-Umbrella Company Fraudrarely trainedElphysic Ltd & Ors v HMRC [2025] UKUT 236 (TCC), 17 July 2025: the Upper Tribunal upheld HMRC's VAT deregistration of… | The Client Engagement | 46% | Missed |
| Investment Migration and Residence SchemesEuropean Commission v Malta (CJEU, Case C-181/23, judgment of 29 April 2025), holding that Malta's… | The Private Client File | 45% | Missed |
| MTIC and VAT Carousel FraudEuropean Public Prosecutor's Office, 5 May 2026: a businessman was arrested in Italy for laundering and reinvesting the proceeds… | The Goods Chain | 42% | Missed |
| Ghost Companies: struck off but still transactingrarely trainedNCA, 16 July 2025: 11,500 UK companies struck off the Companies House register following a multi-agency operation with Companies… | The Client Account | 77% | Partial |
| Cash-Intensive Front BusinessFCA v National Westminster Bank (2021): £264.8m criminal penalty over the Fowler Oldfield account | The Disclosure | — | Partial |
| Charity and Non-Profit AbuseFATF Recommendation 8, amended at the October 2023 Plenary to require risk-based rather than blanket measures, and the… | The Fundraising Appeal | 63% | Partial |
| Legal and Accountancy Client Account MisuseThe Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621), made 9 June 2026 and in force 30 June… | The Client Account | 77% | Partial |
| Mortgage and Property Finance FraudUK Finance, Mortgage Fraud: Good Practice Guidance Note; the FCA's mortgage fraud reporting scheme for lenders and advisers, and… | The Client Account | 77% | Partial |
| Public Funding and Support Scheme FraudInsolvency Service enforcement on Bounce Back Loan Scheme abuse: 1,036 directors disqualified in 2024-25, of which 736 related to… | The Incoming Payment | 65% | Partial |
| Related-Party Circularity in ReceivablesFATF and Egmont Group, Trade-Based Money Laundering: Trends and Developments (December 2020), covering the use of related parties… | The Invoice Pack | — | Partial |
| Services Invoicing with No DeliverableFATF and Egmont Group, Trade-Based Money Laundering: Trends and Developments (December 2020), and the companion FATF Trade-Based… | The Invoice Pack | — | Partial |
| Turnover Inconsistency Against a Physical MeasureAnalytic pattern rather than a single reported case: declared turnover tested against an independent physical measure of activity | The Alert Queue | 79% | Partial |
| Estate Administration and Probaterarely trainedSolicitors Regulation Authority, thematic review of probate and estate administration (13 December 2024): 25 firms visited, three… | The Relationship Review | 83% | Detected |
| Loan-Back Arrangementsrarely trainedFATF, Professional Money Laundering (July 2018) | The Relationship Review | 83% | Detected |
| Necrofinance: dead directors and zombie accountsrarely trainedICIJ Panama Papers investigation (2016) into Mossack Fonseca | The Relationship Review | 83% | Detected |
| Beneficial Ownership ObfuscationThe two largest beneficial ownership regimes moved in opposite directions within a year, and a structure is now easier to hide in… | The Relationship Review | 83% | Detected |
| Bribery Conduits and Consultancy PaymentsOperation Lava Jato: in December 2016 Odebrecht and Braskem admitted paying approximately US$788m in bribes to officials across a… | The Policy Book | 83% | Detected |
| Sanctions-Evasion Ownership RestructuringOFSI and FCDO joint guidance on the meaning of ownership and control under UK sanctions, issued following Mints v National Bank… | The Relationship Review | 83% | Detected |
| TCSPs and Professional EnablersThe Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621), made 9 June 2026 and in force 30 June… | The Relationship Review | 83% | Detected |
How this was measured
Each case is built around one customer who is laundering money. The rate is the share of that customer’s alerts the team caught.
- Detected
- Four fifths of them or more.
- Partial
- Between a half and four fifths.
- Missed
- Half or fewer.
- Untested
- No one has sat a case covering it.
Nothing is reported as detected on the strength of a good overall mark. Findings are suppressed below 3 runs on a case, because a smaller number describes one analyst rather than a team. Methods are declared on the case, not the individual alert, so this reports whether the team detected the method a case is built around rather than scoring each method separately.