With Tranche 2 reforms on the horizon, many law firms are grappling with the same question: How big should our AML team actually be?
The answer isn’t one-size-fits-all. It depends on three key factors:
Onboarding volume – How many new matters do you handle each month?
Complexity – Do you serve high-risk clients or multiple practice areas?
Risk appetite – How much risk is your firm prepared to take on?
Low-Volume Firms (fewer than 50 new matters per month) = One person – usually the AML Compliance Officer (AMLCO) – handles everything: policy, risk assessment, and onboarding.
Medium-Volume Firms (50–200 matters per month) = Two to three people: AMLCO focusing on oversight and policy, One or two Analysts dedicated to onboarding and monitoring.
High-Volume Firms (200+ matters per month) = Four to six people: AMLCO for governance and reporting, Senior Analyst for oversight of daily operations, and several KYC Analysts handling onboarding and due diligence.
Team size isn’t just about numbers. Firms dealing with high-risk clients or multiple practice areas often need extra resources - even if their onboarding volume is relatively low.
A useful rule of thumb? One Analyst for every 30–50 new matters per month. This allows the AMLCO to stay focused on big-picture responsibilities like oversight, policy, and reporting, instead of getting lost in daily onboarding tasks.
Understaffing your AML function doesn’t just increase operational risk. It: Heightens the likelihood of regulatory scrutiny, slows down client onboarding, and leads to burnout and staff turnover. Investing in the right team size upfront can save time, money, and stress down the line.
