Fictional example

See what a Health Check report looks like.

An example of the evidence, observations and practical actions included in a $695 process-level review.

Scope and evidence

One legal entity and five documents or extracts.

The fictional practice has an existing AML/CTF program. The example uses 14 pages in total: a responsibility extract (document 1), blank exception register (document 2), deidentified aggregate task summary (document 3), training and review calendar (document 4), and evidence-storage procedure (document 5). One fictional written clarification round supplements them. No customer files or sensitive matter information are involved.

The three observations below are Amber priorities in this example: operating improvements requiring management attention. A colour is a prioritisation aid, not a legal compliance rating. No Green conclusion is implied for areas outside the agreed review.

Example findings

Evidence connected to a practical next step.

Finding 1 · Amber

Assign responsibility during absence

Evidence and observation. Document 1, page 2: the fictional responsibility extract names the principal but no approved alternate. The example written clarification describes informal cover.

Practical implication. A time-sensitive issue could wait for an authorised decision-maker. No missed legal deadline is established.

Owner and action. Principal: approve cover and decision limits, then run a fictional escalation exercise.

Target and completion evidence. Day 7: approved roles and an exercise record.

Finding 2 · Amber

Link closed tasks to evidence

Evidence and observation. Document 2, page 1: the blank register has no evidence-reference field. Document 3, page 1: the fictional aggregate summary reports 11 closed tasks without identifying evidence locations.

Practical implication. A manager may need to reconstruct why work was closed. This does not establish that underlying evidence is absent.

Owner and action. AMLCO: add evidence reference, closure date and approver fields without copying customer data.

Target and completion evidence. Day 14: revised blank register and a fictional completed example.

Finding 3 · Amber

Review overdue actions consistently

Evidence and observation. Document 3, page 2: the fictional aggregate summary reports four overdue actions. Document 4, page 1: the calendar has no scheduled review of overdue work.

Practical implication. Unresolved work may remain open without a recorded priority or escalation decision.

Owner and action. AMLCO: start a weekly review of owners, due dates and blockers, with principal oversight.

Target and completion evidence. Start by day 7; review deidentified decision summaries by day 30.

Example action plan

Priorities for the next 30 days.

Days 1–7: approve absence cover and begin the overdue-action review.
Days 8–14: add evidence and closure fields, then brief staff.
Days 15–21: check the new routine and resolve blockers.
Days 22–30: record closure or a reasoned extension for remaining actions.

Written report and follow-up

The report sets out evidence references, limitations, actions, proposed owners and target dates. One consolidated question or factual-correction request is included within five working days of receiving the report. Written delivery is standard. Calls can be arranged where needed and agreed in advance. In this example the practice makes changes in its existing system. Remediation or recurring support is considered only if a continuing need is established.

Your practice retains its regulatory responsibilities. The Health Check does not replace an independent evaluation, provide legal advice or guarantee compliance.

Review the standard scope