Regulatory and compliance · MLRO, compliance manager, risk partner
Review a client file against the money laundering rules
A firm's MLRO has pulled a sample of thirty client files ahead of an internal review. The grid reads each file for the due diligence actually evidenced, rather than for the tick on the front sheet.
- First draft
- A file-by-file gap report comes back from one grid run across the sample.
The problem
Step 01 of 05
Load the sample
Thirty client files are uploaded with their matter opening forms, identity documents and any source of funds correspondence.
Project Halcyon: SPA warranties and disclosure
Buy-side warranty review, disclosure analysis and cited due-diligence grid.
- Client
- Halcyon Bidco Ltd
- Reference
- WC-2026-0412
- Practice area
- Corporate / M&A
- Jurisdiction
- England and Wales
- Responsible partner
- E. Vance
No conflict check on file.Chat, on this matter
Compare warranties with the disclosure letter.
Three high-priority exceptions require action: the unregistered charge, the change-of-control right and the tribunal claim.
Send a message… (@ to mention tools)BalancedPrepare for- 25 Aug
Disclosure exceptions matrix
Chat
- 21 Aug
Disclosure exceptions matrix
Run · completed · 560 credits
- 18 Aug
Project Halcyon: Disclosure Letter
Document · indexed
- 16 Aug
Project Halcyon: Share Purchase Agreement
Document · indexed
- 4 Aug
Matter opened
Opened
Step 02 of 05
Write the due diligence columns
Columns cover client identification, verification evidence, beneficial ownership, source of funds, risk rating, enhanced measures where applicable and ongoing monitoring.
Document Parties and effective dateTEXT Term and renewalTEXT Limitation of liabilityTEXT Governing lawTEXT nda-hartwell-meridian.txt saas-agreement-northgate.txt board-minutes-hartwell.txt Step 03 of 05
Run the sample
Each file is answered against every column, with the evidencing document quoted where it exists and the cell marked as unevidenced where it does not.
Document Parties and effective dateTEXT Term and renewalTEXT Limitation of liabilityTEXT Governing lawTEXT nda-hartwell-meridian.txt saas-agreement-northgate.txt board-minutes-hartwell.txt Step 04 of 05
Read the pattern
Source of funds is the weakest column across the sample, and every file rated high risk was opened by the same two fee-earners without enhanced measures recorded.
Document Parties and effective dateTEXT Term and renewalTEXT Limitation of liabilityTEXT Governing lawTEXT nda-hartwell-meridian.txt saas-agreement-northgate.txt board-minutes-hartwell.txt Step 05 of 05
Take the remediation plan
The Audit & Risk Agent produces a ranked remediation list, separating files that need work before the next transaction from those that need a record correcting.
Agent
Jurisdiction
Prepare for
Deliver as
Instruction
What should the agent look for?Documents
Drop a contract, or pick one from the matter
Also on the matter
- Offer_letter_v3.pdf2 pages
- Staff_handbook_2025.docx61 pages
- Board_minute_14_Aug.pdf3 pages
Platform model · zero data retention · audit register on
What comes back
A document, not a transcript.
- A file-by-file grid showing what is evidenced, what is recorded without evidence and what is absent.
- The pattern across the sample, including the weakest check and the two fee-earners it clusters around.
- A remediation list ranked by urgency, separating live risk from record-keeping repair.
- A note on the training point the pattern suggests, framed as an observation for the MLRO.
Authorities it checks
- Money Laundering Regulations 2017, SI 2017/692, regs 27 and 28
- Proceeds of Crime Act 2002, s 330
What it does not do
- It does not make a suspicious activity report or decide whether one is required on any file.
- It does not verify a client's identity or check a document against an official register.
- It does not set the firm's risk appetite; it measures the files against the policy the firm already has.