AML Judgment Gap Report · Full findings
Legal and Conveyancing
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 6 of the 10 money laundering methods that apply to this sector. 4 need action.
3 of these are urgent. Your team was tested on them and missed them.
Your assessment is 7 cases, not one. Each covers a different part of your exposure, and the appendix shows how many of your 10 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 2 methods then and 6 now. 2 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
Legal and Accountancy Client Account Misuse
HighYour team was tested on this and missed it. It sits in The Client Account, which covers 6 of the 10 methods that apply to you.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Client Account — covers 6 of your 10 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?
Client account movements with no underlying legal or accountancy transaction, funds returned to source shortly after receipt, and pooled balances that cannot be reconciled to matters.
90 days · Re-testSit The Client Account again, on the version the team has not seen.
OwnerTarget date - 02
Mortgage and Property Finance Fraud
HighYour team was tested on this and missed it. It sits in The Client Account, which covers 6 of the 10 methods that apply to you.
- Result
- Caught 46% of the laundering customer's alerts.
- Tested by
- The Client Account — covers 6 of your 10 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?
Deposits gifted by parties with no evidenced means, income documentation that cannot be corroborated with the employer or HMRC, valuations materially above comparable sales, and early full repayment shortly after completion.
90 days · Re-testSit The Client Account again, on the version the team has not seen.
OwnerTarget date - 03
Investment Migration and Residence Schemes
HighYour team was tested on this and missed it. It sits in The Private Client File, which covers 2 of the 10 methods that apply to you.
- Result
- Caught 45% of the laundering customer's alerts.
- Tested by
- The Private Client File — covers 2 of your 10 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 - 04
Sport Ownership and Sponsorship
MediumYour team was tested on this and missed it.
- Result
- Caught 39% of the laundering customer's alerts.
- Tested by
- The Sponsorship File — covers 1 of your 10 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?
Club funding by shareholder loan from opaque structures, sponsorship values with no commercial benchmark, agent and image-rights payments routed through unrelated jurisdictions, and transfer fees inconsistent with market.
90 days · Re-testSit The Sponsorship File 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 7 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 Account | 6 | 31% | 14 | 49 | 46% | 3 of 14 |
| The Relationship Review | 6 | 32% | 14 | 87 | 83% | 3 of 14 |
| The Client Engagement | 2 | 11% | 14 | 91 | 89% | 3 of 14 |
| The Private Client File | 2 | 11% | 14 | 48 | 45% | 4 of 14 |
| The Onboarding Interview | 1 | 5% | 14 | 87 | — | — |
| The Policy Book | 1 | 5% | 14 | 87 | 83% | 3 of 14 |
| The Sponsorship File | 1 | 5% | 14 | 42 | 39% | 3 of 14 |
Every method
All 10 methods that apply to this sector, and where each one is documented. Full citations are at amlbenchmark.com/coverage.
| Method | Case | Rate | Result |
|---|---|---|---|
| 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 |
| 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 | 46% | Missed |
| 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 | 46% | Missed |
| Sport Ownership and SponsorshipHM Treasury and Home Office, National Risk Assessment of Money Laundering and Terrorist Financing 2025 (July 2025), paragraphs… | The Sponsorship File | 39% | Missed |
| Engineered Litigation and Court-Ordered Settlementrarely trainedOCCRP, The Russian Laundromat: approximately US$20bn moved between 2010 and spring 2014 through a core of 21 shell companies… | The Relationship Review | 83% | Detected |
| 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 |
| Real Estate: engineered foreclosure and retained controlrarely trainedFinCEN's Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule, in force 1 March 2026 after a postponement… | 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.