ECSH32940 - Using aide memoirs and topic plans

Aide Memoir

An aide memoir is a list of generic questions that can be used in a compliance intervention.

One advantage of an aide memoir is that it can help you formulate what questions you want to ask in advance and can ensure that all areas of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 are covered.

They must not be used as a list of questions to ask in all cases – they are not a script and must be adapted to your case.

The disadvantage is that it is less flexible. You must listen to responses and ask relevant follow-up questions that you haven’t got on your aide memoir as they arise and challenge any conflicting information.  Further guidance on how to ask questions is available in ECSH33005.

You will find a generic aide memoir in the Compliance Investigations section of the knowledge library.

Make sure you know why you’re asking a question and what you will do with the information in the answer.

As part of your planning, you must adapt the aide memoir to suit your case and the risks identified in your initial contact with the business and review of documents. For example, there is no need to ask questions about staff training if you have established there are no relevant staff.

There might be an aide memoir for the specific campaign, project or sector. Ask your Single Point of Contact (SPOC)  – you can find out who this is on the Capability and Learning Zone SharePoint SPOC directory.


Topic plans

The advantage of a topic plan or mind map is that you know the key areas to cover but you’re formulating the questions as you go along. This allows for a fluid discussion between you and the business. It also supports active listening.

The disadvantage is that you might miss asking some important questions if you haven’t prepared thoroughly. If you don’t control the conversation enough, you might end up off-topic or taking up too much of the business’s time discussing topics not relevant to your enquiries; the length and depth of the conversation should be proportionate to the risks.

Your topic plan may consist of:

  • Introductions.
  • Purpose of meeting.
  • Registration and approvals/fit and proper details review.
  • Background/history of the business and operating model.
  • Structure and key personnel within the business.
  • Relevant activity.
  • Assessment of the risks.
  • Transaction process walkthrough/records retained.
  • Policies, controls and procedures discussion.
  • Relevant staff and training.
  • Internal reports/suspicious activity reports (SAR).
  • Select records to test each risk identified.
  • Summarise findings/possible outcomes.