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What internal documents and templates need updating before AML go-live?

Consider changes including for Appointment to Act/Engagement Letters, client communication scripts, cost disclosures, customer-facing FAQs.

Several internal documents need reviewing, drafting and rollout before 1 July 2026. Each one is small individually, but they accumulate quickly if not started early:

  • Appointment to Act / Engagement Letter - reviewed, updated, and signed off by a principal. If you have multiple versions across different matter types, each one needs updating.
  • Client communication scripts - your team will encounter questions or resistance about ID requests. A prepared script or FAQ removes inconsistency.
  • Website, welcome packs, email signatures and auto-responders - email signatures and auto-responders are easy to overlook and may contain out-of-date information.
  • Referrer / introducer briefing pack - a one-page explainer your referrers can share with clients, rather than letting each one improvise.
  • File note standards and matter checklists - your team needs to know exactly what to record and where. Document this before go-live or compliance gaps will appear in audits.
  • Tipping-off policy and staff awareness - under the AML/CTF Act, disclosing that a Suspicious Matter Report has been filed (even to the subject) is a criminal offence. Staff need to understand this before they're in a position where it matters.
  • Records retention schedule - AML records, matter records, accounting records and HR records each have different retention rules. They should sit in one schedule, not spread across people's heads.

Full detail in our Operational Readiness Checklist, Part 1, Sections 7 and 8.

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