Preparing the document room before AML fieldwork
A practical checklist for MLROs hosting on-site AML auditors in Central or branch offices.
Fieldwork slows when auditors wait for credentials, keys, or the one person who knows the archive password. A short preparation week saves more calendar time than adding overtime mid-engagement.
Access
- Read-only rights to CDD and alert systems for named auditors
- Visitor badges arranged before Monday morning
- A room with enough desks for two to three people and a lockable cupboard for paper samples
People
Book interview slots with onboarding, monitoring, and the MLRO early. Double-booking the same officer for a regulator call and an audit interview guarantees slippage.
Paper realities
Hong Kong offices still hold wet-ink forms for older accounts. Label boxes by year and risk segment before auditors arrive. Unlabelled stacks become lost hours.
After hours
If systems cannot be queried during trading peaks, agree evening sampling windows in the engagement letter. Surprises on this point create friction that has nothing to do with control quality.