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 3 of the 8 money laundering methods that apply to this sector. 3 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 5 cases, not one. Each covers a different part of your exposure, and the appendix shows how many of your 8 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 0 methods then and 3 now. Nothing 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 6 of the 8 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 6 of your 8 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 6 of the 8 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 6 of your 8 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 6 of the 8 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 6 of your 8 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
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 5 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 | 6 | 46% | 14 | 49 | 46% | 3 of 14 |
| The Client Account | 3 | 23% | 14 | 87 | 84% | 3 of 14 |
| The Relationship Review | 2 | 15% | 14 | 50 | 46% | 2 of 14 |
| The Fundraising Appeal | 1 | 8% | 14 | 65 | 63% | 3 of 14 |
| The Onboarding Interview | 1 | 8% | 14 | 87 | — | — |
Every method
All 8 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 |
| 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 |
| 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 Onboarding Interview | — | Partial |
| 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 | 84% | Detected |
| Loan-Back Arrangementsrarely trainedFATF, Professional Money Laundering (July 2018) | The Client Account | 84% | Detected |
| 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 | 84% | 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.