When there's a new AML process you are wanting or needing to implement in your firm, do you create a project plan to follow to ensure compliance?
While having a clear plan can help you understand the different elements of what it will take to comply, it's often easier to talk about in theory than actually create and execute one. New processes can feel overwhelming, and with a scarcity of time and budget constraints, it can be difficult to create plans.
Contrary to these challenges, a project plan for your firm's AML compliance can be highly beneficial. A project plan can provide insights and help improve your firm's adherence to regulations and reduce risks linked to money laundering.
The risk of not implementing processes
We understand that you may not always be in control when changes need to be made in your business, especially when the government makes changes that you need to implement. Implementing projects or processes in business poorly can harm compliance. Many individuals know their non-compliance but often admit they lack time to address it. For example, they may say "I know I'm not collecting my clients' IDs properly, but I don't have time to do it differently." Unfortunately, there will be a time when you can't ignore it due to an impending audit and will have to rush through to make last-minute changes. You may as well do it ahead of time. By addressing compliance issues with a thought-through plan in advance, you can reap the benefits in the long term.
Cons of not proper planning
At accounting events, it's common to notice professionals excited about new tools and opportunities. Yet this abundance of enthusiasm can spark impulsive purchase decisions. For instance, after the event, you might go back into your office and casually purchase a software solution like a new T-shirt, thinking it will solve problems that the software promised to fix.
However, this software has created more problems for the firm than previously. This is because:
- An inaccurate understanding of costs: Often, costs aren't considered beyond the software itself, such as the time to install it, learning, and updating policy controls and procedures.
- The cost of abandoning the software: The cost of time when you decide the software actually isn't for you or is too hard; you've wasted time and resources on deciding.
- Loss of good faith with leadership and management: The possible perception of being seen as whimsical or disorganised.
- Future resistance to projects: Leadership sees it as a headache and a cost.
- Personal loss of faith: Doubt in yourself that you can undertake something of that magnitude.
The project plan
Let's walk through the project plan and what each stage would look like if we were implementing a new software.
While the project plan discussed below is designed for implementing a new AML software, it can be adapted for many other use cases you may need in your firm.
Note: Creating a plan is a lengthy process, and feeling slightly overwhelmed is okay. However, the process will speed up once you've reviewed the plan a few times.
Project plan
Your project plan is your mission statement, outlining the who, what, when, where, why and how of your project. This statement is important so you don't get distracted along the way by additional tasks that you may uncover as you begin to work through the project. It also provides you a north star, that you can refer back to to know what your original goal was and what is related to the project
Task identification
Understanding what tasks you need to do to reach your end goal are also important to establishing the project. Spend some time writing down every task you think you'd need to complete for the project. It doesn't matter how small all large, getting a clear picture of what each action will be will help you understand the amount of time it will take to complete. Using post it notes is a great tip here and setting a timer so that you force yourself to sit and think!
Time boxing and prioritising
Once you have your tasks laid out out in front of you, now assign the amount of time you think it will take for you to complete that task. If any tasks is estimated to take longer than 2-3 hours, that task is likely too big to complete in one sitting and likely made up of smaller tasks; add these smaller tasks to your list. You're aiming for small, manageable steps where you can measure your progress. Once you feel you have a good understanding of the tasks you'll need to complete, begin to order them of when they would need to occur e.g. you wouldn't be able to implement a new software without first researching software options! Also consider what would deliver the highest impact first, or what is most critical and schedule that as one of the first tasks for you to complete.
Risk mitigation
How are you going to ensure everything stays on track when handling something as sensitive as AML compliance? You don't want to do more damage than good. The potential worst-case scenario is losing your documentation or exposing your firm to undue risk.
With a clear understanding of the risks involved and the project timeline, you can calculate project costs. You now know how much time it will take to complete tasks, so you can cost this in man hours and software expenses, e.g., the monthly or annual subscription cost, alongside the amount of time it takes to implement it!
Project review and stakeholder management
Project implementation
Okay, so your approval has been granted(did you have to chop off your hands to get it?).. This allows you to progress to the implementation phase of your project. This is where we do the doing! Set yourself a deadline for when you want the project to be completed, this will help the project not run over time. Also set yourself some incentives, is there something in particular that would motivate you to get the project finished? We'd also reccomend using a task manager or setting your calendar up to manage tasks so you will get notifications and reminders for your project.
How to use ChatGPT for this project
You can streamline and increase the pace of your project by using AI like ChatGPT. To get started, you can:
- Review the price of similar software providers to get an understanding of the 'median' price
- Research the key features you require for your firm and what are the 'nice to haves'
- Usability and UI
- Create an onboarding and implementation program
Wrapping up project management principles</H2>
To recap, when a new AML process needs to be implemented, the thought of it does not need to be overwhelming. With a structured project plan, you can increase your firm's efficiency in adhering to compliance and reducing risks.
At Firmcheck, we know the main challenges firms face when it comes to planning, namely a scarcity of time and budget constraints. That's why we stress the importance of planning in advance before any last-minute changes are needed. If in doubt, use ChatGPT or AI tools to help speed up your project planning.
With clear objectives, task prioritization and risk management strategies, you can enhance your firm's efficiency with compliance.
We discussed project management principles for AML compliance in more detail in February- Learn about them in our MLRO 2025 Summit.
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