AML — Anti-Money Laundering in International Payments

Last reviewed: · Curated by Ohmyfin Organisation editorial.

AML (Anti-Money Laundering) refers to the legal and procedural controls that banks apply to detect and prevent money laundering, terrorism financing, and other financial crimes in the flow of international wire transfers. Track any delayed wire free on Ohmyfin →

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Every bank processing a cross-border SWIFT payment is legally required to apply AML controls under the laws of its jurisdiction. In the US, these requirements come from the Bank Secrecy Act (BSA) and FinCEN regulations. In the EU, successive Anti-Money Laundering Directives (currently AMLD6) set the standard. In the UK, the Proceeds of Crime Act 2002 (POCA) and FCA rules apply. In practice, every major correspondent bank screens every payment — not just those obviously suspicious.

AML screening covers: (1) Name screening — comparing sender, beneficiary and any other named parties in the payment against sanctions lists (OFAC SDN, EU Consolidated Sanctions, UN Security Council, HMT, etc.) and adverse-media databases; (2) Transaction monitoring — checking the amount, frequency and pattern of payments against the customer's profile; (3) Purpose of payment — some jurisdictions require a stated purpose code and will hold payments without one; (4) Beneficial ownership — for business payments, verifying who ultimately controls the sending entity.

The "False Positive" problem: automated AML screening generates many false positives — payments placed on hold because a name happens to partially match a sanctioned entity. A payment from "Hassan Ahmed" may trigger a hold because the name overlaps with a sanctioned individual, even when the actual sender has no connection. Banks must manually review these cases before releasing the payment, which typically takes 1–3 business days and is a major source of otherwise-unexplained ACWP (Accepted With Pending change) status codes.

When Ohmyfin shows a payment in ACWP status for more than 24 hours with no new updates, an AML hold at a correspondent bank is the most likely cause. The remedy is to contact your bank's investigations team and provide additional KYC documentation if requested — sometimes a simple letter of explanation or invoice is enough to release the hold.

The FATF (Financial Action Task Force) sets global AML standards and reviews countries' compliance. Countries rated "grey-listed" or "black-listed" by FATF face heightened scrutiny on all incoming/outgoing payments, with correspondent banks applying enhanced due diligence (EDD) that adds review time. Pakistan, Nigeria, Myanmar and others have been on the FATF grey list, affecting corridor timing significantly.

Key facts

Frequently asked questions

Why is my wire transfer on hold for AML?

An automated screen found a potential match against a sanctions list or triggered a transaction-monitoring rule. A compliance officer must manually review the payment. Provide your bank with any supporting documents they request — source of funds, invoice, purpose of payment letter — to speed up the review.

What is KYC in relation to AML?

KYC (Know Your Customer) is the identity-verification process banks use when onboarding customers and when monitoring transactions. It feeds AML: a complete, up-to-date KYC file (ID, address, source of funds, business purpose) speeds up AML review because the compliance officer has context to clear borderline cases quickly.

Can I do anything to prevent AML delays?

Yes: (1) use consistent beneficiary details that exactly match their bank account name; (2) always include a clear purpose of payment; (3) avoid large one-off amounts to new beneficiaries without prior context; (4) maintain a complete KYC file with your bank. Payments to new beneficiaries in high-risk corridors (FATF grey-listed countries) should be expected to take longer.

How is AML screening different from sanctions screening?

Sanctions screening is a subset of AML — it checks against specific government-issued lists of designated individuals, entities and countries. Broader AML includes transaction monitoring, enhanced due diligence, source-of-funds checks, and suspicious activity reporting. Sanctions hits are usually more serious and harder to clear than other AML holds.

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