Tipping-Off, DAML and Client Exit Procedure

What to do after an internal report or SAR – DAML timetable and record, safe wording for client questions, professional clearance and resignation, handling subject access requests and law enforcement requests.

Editable Word document
6
10pages
Guidance notes included
aml consultancy solutions

Accountancy practice – compliance & management

Tipping-Off, DAML and Client Exit Procedure

About this document

What it’s for

A step-by-step procedure for the MLRO and staff once money laundering is known or suspected: whether to stop work, requesting a defence against money laundering (DAML) from the National Crime Agency, managing the notice and moratorium periods, communicating with the client without tipping off, ceasing to act, answering professional clearance requests and responding to production orders.

When to use it

  • As soon as an internal report has been made about a current client
  • When a DAML is needed to continue work or deal with funds
  • When ceasing to act for AML reasons, or answering a clearance request about a client you have reported

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  • Part 1 – Immediate steps after an internal report
  • Part 2 – DAML record
  • Part 3 – Ceasing to act
  • Part 4 – Neutral wording
  • Part 5 – Subject access and law enforcement requests

How to complete it

  • The MLRO completes the DAML record and approves all client communications
  • Use the neutral wording in Part 4, adapted as needed, and keep a record of what was said
  • Keep this record in the MLRO’s confidential file, never on the client file

Key points to check

  • Updated for the Money Laundering Regulations as amended by SI 2026/621 and the CCAB 2026 guidance
  • Tailor it to your firm before use

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

Included in the pack

Accountancy practice – compliance & management

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Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

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