JMLSG guidance is the yardstick regulators will likely use when assessing your systems and controls. So when you’re reviewing your compliance framework, start by asking: how closely do we track the current JMLSG guidance?

Use the guidance to make risk-based decisions that are proportionate, practical, and justifiable. If your customer risk assessment model doesn’t reflect the risk factors outlined by the JMLSG, you could be missing high-risk customers or applying controls where they’re not needed. 

When auditors or regulators come knocking, one of the first things they’ll look at is whether your policies align with industry-recognised best practices. Saying you “follow JMLSG guidance” is easy enough but what they’re really looking for is evidence that you’ve understood it and built it into your controls. That means documenting your reasoning, especially when you take a different approach. JMLSG encourages proportionality, but it has to be based on a proper rationale, not convenience.

Training is another area where JMLSG guidance has a real impact.  Your staff need to understand the “why” behind your controls, and the guidance gives you a strong foundation to build training that’s relevant and keeps people alert to real-world risks. 

Then there’s ongoing monitoring. JMLSG is clear that this isn’t a once-a-year job. Your controls need to evolve with your risk profile, your customer base, and the wider environment. So if you’re not already using the guidance as a benchmark for reviewing monitoring triggers, alerts, and escalation processes, you’re missing a key opportunity to keep your system fit for purpose.

In short, the JMLSG won’t tell you exactly how to run your AML function but it sets the boundaries, and if you can demonstrate you’re working within those, you’re already starting from a stronger position. Use it not as a checklist, but as a tool to sharpen your approach. Make sure your policies, your controls, and your people all reflect the standards it sets out.