Account Monitoring Order (AMO) definition and meaning | AML glossary
Account Monitoring Order (AMO) definition: What it means in AML compliance.
An Account Monitoring Order (AMO) is an essential tool in the regulatory landscape, enabling authorities to monitor transactions on a specific account for a set period, usually up to 90 days, with the potential for extension. Unlike an Account Freezing Order (AFO), which restricts account activity, an AMO allows law enforcement agencies to observe account movements without directly intervening in day-to-day transactions and activity. For a compliance officer, understanding when and how AMOs are issued is integral to maintaining a balance between your company’s obligations and your customers’ rights.
When an AMO is applied, authorities are granted the ability to monitor transactions on an account suspected of involvement in illegal activities such as money laundering, terrorist financing, or fraud. This monitoring is particularly valuable when there is insufficient evidence to justify freezing an account entirely but when authorities believe ongoing surveillance is necessary to build a clearer picture of the suspect’s financial activities. As a compliance manager, you may not be directly involved in obtaining the order, but you will likely be expected to assist in monitoring and flagging suspicious transactions as part of your company’s commitment to regulatory compliance.
One key aspect of AMOs is that they provide law enforcement with insight into the activities of individuals or entities that may be engaging in financial crime. Authorities can monitor incoming and outgoing transactions and examine patterns that may reveal hidden links to illicit activity.Â
“Account monitoring orders enable investigators to obtain an order from the court requiring a financial institution to provide information about accounts held with it. The period for which the information is required to be given is a maximum of 90 days.”
Gov.uk
Financial and property investigation powers: National Security Bill factsheet
Why Account Monitoring Orders (AMOs) matter for compliance teams.
For AML professionals, an AMO is a legal obligation that requires careful handling. If your institution receives an AMO, you’ll need to monitor transactions on the specified account and report them to law enforcement, often in strict secrecy. The person or business under investigation cannot be made aware of the order, which means your team must ensure that routine interactions, customer service, or internal processes don’t accidentally reveal that monitoring is taking place.
Handling an AMO also means working closely with law enforcement while staying within the boundaries of data protection and confidentiality laws. The request will specify what types of transactions or activity need to be reported, how often, and for how long. Your role is to ensure the data is collected accurately and provided in the right format without interfering with day-to-day operations.
From a practical standpoint, this requires you to ensure that your internal systems are capable of tracking the necessary details, including the account holder’s identity, transaction history, and any notable patterns that could suggest illicit activity. This is where your role as an AML compliance manager becomes vital in ensuring that transactions and activity flagged by your systems are appropriately escalated and investigated.
Another important feature of AMOs is their ability to support ongoing investigations. Since these orders allow law enforcement to keep tabs on a suspect’s account for an extended period, they can gather data that may help in building a case for further action, including asset freezing or criminal charges. As part of this, your responsibility as a compliance team is to coordinate with the relevant authorities to ensure that transaction data is provided accurately and promptly, as failing to comply with these requests could result in serious legal repercussions.
Failure to follow the requirements of an AMO properly can lead to regulatory scrutiny, reputational damage, and legal consequences. On the other hand, responding effectively strengthens your institution’s relationship with regulators and reinforces its commitment to stopping financial crime. AMOs are not everyday occurrences, but when they do come in, they need to be treated with precision and discretion.
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