AML Compliance Checklist: 10 Controls Regulators and Partners Expect

If your business touches money, you’re running a target for bad actors. And they don’t knock first. They test weak spots like a thief trying doors on a quiet street.

An AML compliance checklist gives founders and small teams a clear way to build controls before a bank, partner, or regulator asks hard questions. It’s also how you protect your brand when you’re moving fast, shipping features, and onboarding customers at scale.

This guide is written for startup founders, marketers, and small business owners launching financial business ideas like payments, fintech SaaS, iGaming, lending, crypto services, marketplaces, or any product that moves value.

Who actually needs AML (and why startups get surprised)

If you’re a “reporting entity” or you work with one, AML expectations can land on your desk even if you’re not a bank. That includes many fintechs, payment facilitators, money service businesses, wealth managers, iGaming operators, and companies handling cross-border funds.

Even when you’re not directly regulated, partners often require AML controls as part of vendor onboarding, payout access, or banking relationships.

For a non-US example of what regulators expect in plain terms, AUSTRAC’s updated December 2025 quick guide is a useful reference: AML/CTF program quick guide.

AML compliance checklist: 10 controls regulators and partners expect

Below are ten checklist items that work as a practical build order. Treat them like the smoke alarms in your house: you install them before the fire.

1) Assign an AML owner (and give them authority)

Summary: Name a compliance lead (even part-time) with decision rights.
Why it matters:

• No owner means no action when risk shows up
• Audits fail on “unclear accountability”
  Who it’s for: Any team handling payments, payouts, or stored value.
  How to start: Write a one-page responsibility map for approvals and escalations.
  Tools: Notion or Google Docs for RACI and policies.
  Example: A payment startup routes all high-risk alerts to one accountable person.

2) Document your AML program (policy plus procedures)

Summary: Put your rules in writing, then match daily actions to them.
Why it matters: Written programs reduce inconsistent decisions.
Who it’s for: Fintech, iGaming, crypto, payroll, remittance, and lending.
How to start: Draft sections for CDD, EDD, monitoring, SAR reporting, and training.
Tools: Templates can help, but tailor them to your flows.
Example: An iGaming operator keeps licensing-ready documentation (see iGaming License Compliance Documentation Guide).

3) Run a risk assessment (products, geos, customers, channels)

Summary: Score where money laundering risk is most likely in your business model.
Why it matters: A risk-based program prevents “one-size-fits-all” controls.
Who it’s for: Everyone, especially marketplaces and cross-border services.
How to start: Rate risk across customer type, transaction size, geography, and funding method.
Tools: A simple spreadsheet works for early-stage teams.
Example: A marketplace flags higher risk when sellers request third-party payouts.

4) Build Customer Due Diligence (CDD) and KYC workflows

Summary: Verify identity at onboarding and keep records of what you checked.
Why it matters: You can’t monitor behavior if you don’t know who’s behind it.
Who it’s for: Any product with accounts, wallets, payouts, or credit.
How to start: Define required fields, document checks, and pass or fail outcomes.
Tools: Identity verification vendors can shorten setup time.
Example: A fintech uses automated ID checks for faster approval and fewer fake accounts.

A practical overview of what to include is here: AML Compliance Checklist: Best Practices, Tools, & ….

5) Identify beneficial owners and controllers (where applicable)

Summary: For business customers, capture ownership and control structure.
Why it matters: Shell companies exist to hide the real actor.
Who it’s for: B2B fintech, payouts, lending, and merchant services.
How to start: Require ownership details at onboarding and refresh on material changes.
Tools: Intake forms plus verification checks.
Example: A lender collects ownership data before approving a credit line.

Note: beneficial ownership reporting rules and timelines can change, so confirm current guidance for your jurisdiction and program scope.

6) Apply Enhanced Due Diligence (EDD) for high-risk cases

Summary: When risk is high, your checks should go deeper.
Why it matters: High-risk customers create most enforcement exposure.
Who it’s for: Firms with cross-border activity, high transaction limits, or cash-heavy sectors.
How to start: Define EDD triggers (PEPs, sanctions hits, unusual funding sources).
Tools: Case management workflows in Jira, Asana, or a compliance tool.
Example: A remittance app requests source-of-funds proof above set thresholds.

7) Screen sanctions, watchlists, and PEPs

Summary: Check customers and related parties against relevant lists.
Why it matters: A single prohibited party can cause account freezes and partner loss.
Who it’s for: Any business with international customers, payouts, or vendors.
How to start: Decide when to screen (onboarding, payout, ongoing).
Tools: Screening providers or bank partner tools.
Example: A payroll platform screens directors before enabling contractor payouts.

8) Set up transaction monitoring (rules you can explain)

Summary: Detect patterns that don’t match expected customer behavior.
Why it matters: Monitoring is how you catch issues after onboarding.
Who it’s for: Wallets, payment processors, crypto on-ramps, iGaming, lending.
How to start: Start with simple rules (velocity, amount, geos), then tune monthly.
Tools: Analytics plus alerts; some teams add ML later.
Example: An iGaming site flags rapid deposits followed by fast withdrawals.

If you’re considering automation, this overview helps connect AI to compliance work without hype: Generative AI Impact on Financial Compliance.

9) Create escalation paths and suspicious activity reporting (SAR)

Summary: Define what happens when an alert looks real.
Why it matters: Delays and confusion are what audits punish.
Who it’s for: Teams with alerts, chargebacks, disputes, fraud, or compliance queues.
How to start: Write a short playbook: triage, investigate, decide, document, report.
Tools: A ticketing system plus a decision log.
Example: An analyst escalates to the AML owner within 24 hours for repeat patterns.

For a legal-practice-oriented view of what “good” looks like, see: Anti-money laundering compliance: checklist | Practical Law.

10) Training, audits, and recordkeeping (the boring parts that save you)

Summary: Train staff, test controls, and keep evidence that you did the work.
Why it matters: Regulators and partners want proof, not promises.
Who it’s for: Every business with an AML program.
How to start: Quarterly training, annual independent review (scope-based), retention schedule.
Tools: LMS for training, shared drive for audit evidence, calendar reminders.
Example: A small fintech keeps a folder per month with alerts, decisions, and outcomes.

Quick comparison: low-cost tools to manage AML work

Tool or platform type	Best for	Starting cost	Key benefit
Google Sheets or Excel	Early risk assessment and logs	Free to low	Fast setup, easy audits
Notion or Confluence	Policies and procedures	Free to low	One source of truth
Jira or Asana	Case management	Free to mid	Clear ownership and timelines
BI tools (Looker, Power BI)	Monitoring dashboards	Varies	Trend visibility and reporting
Commercial KYC/AML vendor	IDV, screening, monitoring	Quote-based	Less manual work at scale

If your finance team also owns cash movement and approvals, tighter treasury controls reduce operational risk alongside AML controls (see Treasury Operations and Regulatory Compliance).

How to choose the right AML setup (a decision checklist)

• Your exposure: Do you move funds, enable payouts, or touch cross-border flows?
• Your customer type: Consumers, SMBs, or high-risk verticals (gaming, crypto, adult, etc.).
• Your transaction profile: High frequency, high value, refunds, chargebacks, cash-like funding.
• Partner expectations: Bank sponsor, payment processor, marketplace payout provider.
• Your team capacity: Who investigates alerts, and how fast can they respond?
• Your evidence plan: Can you show decisions, approvals, and training history in a review?

Conclusion

AML isn’t a one-time task, it’s an operating habit. When you treat your program like a working system (owners, rules, monitoring, and proof), you protect revenue, partnerships, and brand trust.

Use this AML compliance checklist to pick a realistic baseline, then improve one control each month. Your future self, your bank partner, and your customers will thank you.