AML Complete was mandated by the IAB in 2023 as part of our approach to strengthening supervision and ensuring consistent standards across all IAB supervised members.
While you may continue to use your existing AML systems to support your internal processes, this does not replace the requirement to use AML Complete. Members are still expected to maintain their AML records within AML Complete, as it forms part of the IAB’s supervisory framework and enables effective oversight of compliance across the membership.
AML Complete provides a standardised structure for capturing key information such as client due diligence, risk assessments, and policies, and allows the IAB to identify trends, risks, and areas where further guidance or intervention may be required.
In practice, this means AML Complete must be used as the primary system for evidencing compliance to the IAB, even where additional tools are used alongside it. This ensures both consistency and transparency, and supports members in demonstrating that they are meeting their regulatory obligations in a clear and auditable way.