Regulatory, business model, perimeter, payment, gaming, crypto-asset and cross-border opinions that answer what banks and investors ask.
AML & Financial Crime Compliance
AML/CFT compliance built on your actual risk profile: documented for the regulators, banks and auditors who review it, and practical for your team to run.
Discuss your matter
Typical deliverables
- AML/CFT programme and governance map
- Enterprise-wide risk assessment
- AML/CFT and sanctions policy set
- KYC/KYB, CDD and EDD standards
- Monitoring scenarios ready to configure
- Audit report and remediation plan
A cross-jurisdiction capability, supported across the jurisdictions in our directory. See jurisdictions
Dedicated services
Instructed on their own
- ServiceMLRO-as-a-ServiceAn experienced MLRO, a deputy or support to your own MLRO, with clear accountability and decisions documented for supervisory review.
- ServiceIndependent AML/CFT AuditSee how your AML/CFT controls perform on real files and alerts, through independent testing that ends in a shareable report and a remediation plan.
Overview
Why it matters
Your AML/CFT framework has to work in practice, not only on paper: a risk assessment that reflects your actual customers, policies written for your products and monitoring tuned to real activity. That is what regulators test at inspection, and where copied or generic frameworks draw findings.
We design AML/CFT and sanctions programmes from your own enterprise-wide risk assessment upward, provide experienced MLRO capacity, carry out independent AML/CFT audits that show where you stand before a regulator, bank or payment partner does, and see remediation through to evidenced closure.
Banks, acquirers and payment partners examine the same framework at onboarding and in periodic reviews. A programme built to regulatory standard also gives you consistent, documented answers for those reviews, which supports keeping banking and payment access.
Scope
What we do
AML/CFT Compliance Programme
Design or rebuild of the whole programme: governance, risk assessment, policies, customer due diligence, monitoring, reporting, record-keeping and training.
MLRO-as-a-Service
An experienced MLRO, a deputy MLRO or structured support to the MLRO you appoint, covering suspicion reporting, oversight of controls, board reporting and regulator and bank liaison.
Independent AML/CFT Audit
Independent testing of the design and effectiveness of your AML/CFT framework, with rated findings, a prioritised remediation plan and a report you can share with banks.
Enterprise-Wide Risk Assessment
A documented assessment of customer, product, delivery channel and geographic risk that drives the controls in every other part of the programme.
KYC / KYB / CDD / EDD Frameworks
Onboarding, verification and due diligence standards for individuals and businesses, including beneficial ownership, source of funds and source of wealth.
Transaction Monitoring Frameworks
Scenarios and thresholds calibrated to your products, alert handling and escalation workflows, and support with selecting monitoring vendors.
Sanctions & PEP Compliance
Screening scope, list management, match handling and escalation for sanctions and politically exposed persons.
AML Policies & Procedures
Policies, procedures and controls written for your products, customers and jurisdictions — and for the people who have to apply them.
AML Remediation
Structured remediation of audit, inspection or bank findings: root-cause analysis, look-backs, file remediation and evidence of closure.
Regulatory Inspection / Examination Support
Preparing for inspections and examinations, supporting management during the visit and responding to findings.
Jurisdictions
Supported across jurisdictions
We support AML & Financial Crime Compliance across the jurisdictions in our directory, adapting the work to what each jurisdiction's law requires and coordinating local specialists where local law, registration, representation or professional requirements require it. MLRO-as-a-Service is set up around each regulator's requirements.
- Europe18
- Asia & Middle East4
- Americas & Caribbean11
- Africa & Indian Ocean6
Industries
Where we apply it
- iGaming & GamingB2C operators, B2B suppliers, platforms, aggregators and affiliates.
- Fintech & PaymentsPayment and e-money institutions, PSPs and acquirers, payment facilitators and embedded finance.
- Crypto & Digital AssetsCASPs and VASPs, exchanges, custodians, wallets, token projects and crypto payments.
- Forex & InvestmentsForex and CFD brokers, investment firms, trading and investment platforms.
- Digital Platforms & MarketplacesOnline marketplaces, digital platforms, multi-sided platforms and digital service operators.
- IT & SaaS BusinessesIT and software development companies, SaaS providers, IT outsourcing and cloud services.
Questions
Frequently asked
Can you act as our MLRO?
Yes. Through MLRO-as-a-Service we act as your appointed MLRO, as your deputy MLRO or as interim cover, in an arrangement set up around your regulator's requirements; where those call for an in-house or resident MLRO, we support the MLRO you appoint.
We have an inspection coming up. Can you help us prepare?
Yes. A pre-inspection review focuses on the areas regulators typically test — risk assessment, customer files, monitoring outcomes and governance — and gives you time to remediate before the visit.
Our bank has asked about our AML framework. What should we send?
Usually a summary of the programme, the latest risk assessment, key policies and, increasingly, the most recent independent audit and the status of its findings. We prepare a consistent pack so that the answers match what the bank has already seen.
Related
Related practice areas
Bank account opening, merchant accounts, acquiring, payment flows and safeguarding for international businesses, including gaming, crypto, forex and other high-risk models.
External DPO services and working privacy programmes: GDPR and global privacy laws, DPIAs, data mapping, transfers and ISO/IEC 27701.
Licence strategy, applications and regulator engagement for gaming, payments, e-money, investment and crypto-asset businesses.
Need an AML programme, an MLRO or an independent audit?
Tell us about your business, products and any inspection or bank review ahead. We discuss what the work involves and where to start, then send a written proposal with scope, timetable and fee.