Smarter AML starts with a risk-based approach

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Sinead Haycox headshot
Sinead Haycox
July 17, 2025
5
min read
AML
AML Compliance
Automate
Compliance
PEPs

In today’s rapidly evolving financial landscape, the threats posed by money laundering are increasingly complex. Not only that, but they are also well-resourced and globally connected, making compliance more challenging than ever before.

To effectively combat this, a risk-based approach (RBA) to AML is now the gold standard. Rather than applying one-size-fits-all compliance measures across the board, a risk-based approach allows organisations to focus their resources on areas that pose the highest threat of financial crime, allowing businesses to allocate time and effort efficiently whilst also meeting regulatory requirements.

What is a risk-based approach?

A risk-based approach is a method of AML compliance that strategically prioritises controls based on the level of required scrutiny due to the risk presented by clients, transactions, products, and jurisdictions. It enables businesses to:

  • Identify potential risks of money laundering and terrorist financing.
  • Assess the likelihood and impact of those risks.
  • Mitigate them using targeted controls and monitoring.

This approach is not only best practice, but also required under UK law and international standards, including those established by the Financial Action Task Force (FATF).

Why would I need a risk-based approach?

A risk-based approach helps businesses focus their efforts on clients and transactions that pose the highest risk of financial crime. By concentrating resources where they are most needed, organisations can improve the effectiveness of their compliance programs while optimising time and cost. Rather than applying the same level of scrutiny across the board, a risk-based method allows teams to prioritise high-risk cases, ensuring that warning signs are not missed.

This approach also enables businesses to meet AML regulations more efficiently. Regulators increasingly expect companies to demonstrate that they are actively assessing risk and applying controls proportionate to those risks. A risk-based framework not only helps to meet these obligations but does so in a way that preserves resources and enhances compliance.

Additionally, a risk-based strategy empowers businesses to proactively identify and mitigate risks before they escalate. With the right tools and data, early warning signs such as unusual transactions or connections to high-risk jurisdictions can be spotted and addressed swiftly, before it is too late.

Key steps in implementing a risk-based approach

So, what can your business do today to start your RBA approach within your AML strategy? It's important to start at the very beginning with a thorough client review, before taking a deeper dive and completing the necessary actions. Undertaking this manually is time consuming and prone to human error, it is recommended that you utilise software like Red Flag Alert's Compliance solution to help support your AML strategy.

You should:

1. Conduct a risk assessment

Begin by identifying and evaluating the risks associated with your clients, the nature of their transactions, the industries they operate in, and the geographies they are connected to. This foundational step informs all subsequent decisions and will help you understand your exposure from the outset.

2. Categorise and score risks

Once identified, assign risk levels (e.g., low, medium, high) to clients or transactions using a structured framework. This classification helps tailor your due diligence and monitoring efforts accordingly.

3. Implement proportionate controls

Apply appropriate controls based on the risk level. Apply Enhanced Due Diligence (EDD) for high-risk clients, such as additional identity checks, source of funds verification, and more frequent monitoring.

4. Continuously monitor and review

AML risk is not static. Review your risk assessment regularly based on changes in behaviour, legislation, or internal controls. Update your risk assessments as needed when new information arises.

By embedding these steps into your AML program, your business can remain agile, compliant, and prepared to respond to emerging threats with confidence.

Why is a risk-based approach so important?

A risk-based strategy is essential for AML professionals because it enables:

1. Focus on high-risk areas

Not all customers or transactions pose the same risk. RBA allows professionals to concentrate enhanced due diligence efforts on customers that may be deemed as high-risk because of their specific country or territory. It may also apply to politically exposed persons (PEPs) or those with complex ownership structures.

2. Efficient use of resources

Manual AML compliance is time-consuming and costly. When using a risk-based approach, particularly if you use a tool like Automate, resources are spent where they matter most. This reduces unnecessary checks on low-risk customers and allows for staff to be reallocated as needed.

3. Proactive risk mitigation

When it comes to risk, change from a reactive to a proactive approach. Rather than scrambling after a crime occurs, RBA encourages the identification of emerging risks weeks or months before the issue arises, and enables businesses to implement early controls.

4. Stronger regulatory compliance

Regulators expect financial institutions and regulated businesses to adopt a risk-based framework. Non-compliance can result in fines, reputational damage, and even criminal liability for directors and staff.

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Benefits of a risk-based approach

A risk-based approach to AML offers numerous benefits for organisations looking to stay compliant and operate efficiently. Here are the key advantages:

  • Improves resource allocation by prioritising high-risk areas.
  • Enhances the detection and prevention of financial crime.
  • More effective detection of suspicious activity.
  • Compliance with AML laws and regulations, so no fines down the line.
  • Greater operational efficiency and reduced false positives.
  • Enhanced decision-making and better client onboarding processes.
  • Lower overall cost of compliance through targeted resource use.
  • Protects the reputation of the business.

Non-compliance is not an option

UK anti-money laundering legislation puts a tremendous amount of responsibility on the private sector and has intentionally harsh punishments for those who have been found to be negligent. Regulatory bodies such as the FCA, HMRC, and SRA have made it clear that ignorance is no defence and that organisations must have documented policies and robust systems to provide clear accountability if and when something does go awry.

Companies need to ensure that all relevant staff are trained in anti-money laundering and understand what their obligations are, AML compliance Anti-money should be thought of as a non-negotiable to be applied in the daily function of a business. Directors and senior management are personally liable for failures, and penalties for non-compliance include hefty fines and criminal sanctions. AML must not be seen as a simple checkbox to keep the regulators happy.

How Red Flag Alert supports a risk-based AML strategy

With Red Flag Alert, you can onboard and monitor your clients in one secure, compliant platform. Our customers save time, reduce risk, and ensure peace of mind.

Red Flag Alert's Compliance solution provides:

  • Unbeatable match rates
  • Digital IDV checks
  • Advanced due diligence
  • UBO down to 0.1%
  • A full suite of risk checks
  • Real-time PEPs and sanctions checks
  • Time and cost-saving automation
  • Ongoing support for users

Get in touch to discover how Red Flag Alert can help you identify high-risk clients, monitor in real-time, and stay one step ahead of financial crime. Or find out even more about an AML risk-based approach, by downloading our AML Risk Assessment Guide.

If you want to find out how Red Flag Alert helps regulated businesses implement and maintain a comprehensive RBA through our industry-leading AML software, contact one of our AML specialists today.
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