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What sensible Tranche 2 preparation actually looks like

  • Feb 16
  • 2 min read

Author, Amy Bell, CEO and Founder of AML Sorted


AML Sorted explains how to understand anti-money laundering compliance risk ratings, SDD, CDD and EDD easily

This is not a moment for panic and it is certainly not a moment for copying and pasting bloated AML manuals that no one understands.


One of the most common issues we see is firms being handed documents that are:

  • poorly structured

  • internally inconsistent

  • overloaded with formulas and scoring without explanation

  • unclear on whether risk applies to individuals or entities

  • mixing risk assessment content into policy documents


This creates confusion where it doesn’t need to be, not compliance.


The foundation: a standalone risk assessment


A defensible AML framework starts with a clear, standalone risk assessment. That document should:


  • clearly explain why risks exist

  • distinguish between customer, service, geographic and delivery channel risks

  • be understandable by the lawyers and others in the firm who are expected to use it

  • inform your policies


“Your risk assessment should lead your policies, not be buried inside them”

Policies should then sit around that risk assessment, not replace it.


What regulators will want to see


When Tranche 2 goes live, the firms that will fare the best will be able to show:


  • they understand their specific risk profile

  • they have taken proportionate steps to address it

  • their lawyers and those supporting them know when AML issues arise

  • they are improving over time


This is about defensibility, not box‑ticking.


The real takeaway Tranche 2 preparation is not about perfection. It’s about: understanding your risk, starting sensible processes, training your people, communicating clearly with clients and being able to evidence progress.


At AML Sorted, our position hasn’t changed: calm, practical preparation wins. We’ll continue to cut through the noise, clarify expectations and help firms build frameworks that actually work, not just on paper but in practice too. If you’d like help sense‑checking where your firm is at, or understanding what sensible preparation looks like for your practice, that’s exactly what we’re here for.


Thanks for reading and if you'd like to understand more about how AML Sorted can support you and your firm, why not drop us an email?







 
 
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