AML Register - Step by step review
To complete, the review form is a step-by-step flow. Later steps in the process stay locked until the earlier ones are done.
Step 1 — Acknowledge the review
Tick the confirmation that you have reviewed the patron details, payout history, compliance context, and triggered risk indicators. Nothing else can be filled in until this is done.
Step 2 — Record your decision
Answer the question "Does this matter present an AML or suspicious matter risk?":
- Yes, risk identified
- No, false positive / no risk identified
Step 3 — Record the actions taken (only when a risk was identified)
Select every action that applies. The most common actions are shown first; select Show more
Actions for the full list. Options include:
- Suspicious Matter Report submitted
- Enhanced customer due diligence initiated
- Additional information requested from staff / from patron
- Source of funds or wealth requested
- Payout and transaction history reviewed
- Related patrons, accounts or payouts reviewed
- Patron ML/TF risk rating increased
- Patron added to internal watchlist
- Enhanced ongoing monitoring applied
- Future payouts require compliance review
- Internal investigation or incident created
- External AML advice obtained
- Payout or service temporarily paused under venue policy
- Payout or service restricted or declined under venue policy
- Customer relationship restricted or ended
- No further action required
- Other (with a required free-text description)
At least one action is required when a risk is marked as identified.
Step 4 — Adjust the risk score (optional)
The risk level that was chosen at the time the Manager reviewed the payout is shown. During this review, If your assessment differs, select High, Medium, or Low to override it. The override is recorded as the manager risk rating on the payout itself, and the change is captured in the payout’s audit log.
Step 5 — Review notes
Document your explanations and any additional context. Notes are part of the permanent record, so write them as you would want an auditor or regulator to read them.
Step 6 — Save
Once saved, the status automatically changes from Awaiting Review to a final status (dependant on the outcome of your review):
|
Your review |
Resulting status |
|
No risk identified |
Closed — No further action |
|
Risk identified + "Suspicious Matter Report being prepared" |
SMR in progress |
|
Risk identified + "Suspicious Matter Report submitted" |
SMR submitted |
|
Risk identified, any other actions |
Closed — Monitoring |
After the review
- Completed reviews are read-only. Opening the entry from the Actioned Risks tab shows the recorded decision, actions, risk level, and notes, but they cannot be edited. This protects the integrity of the compliance record.
- Supporting documents can be attached at any time. During the review or after it is complete. Use the Supporting documents button to upload files (for example an SMR receipt, correspondence, or CCTV stills), view them, or remove them. Every attachment and removal is audit-logged with who did it.
- Use the Export PDF feature to generate a PDF of the current view (Awaiting Review tab or Actioned Risks tab), with or without applied filters.