Compliance & AML/CFT Implementation

Every credible AML/CFT framework starts from a documented business-wide risk assessment — the foundation regulators expect to see and the reference point your controls are calibrated against. We assess inherent money-laundering, terrorist-financing, proliferation-financing and sanctions risk across your customer base, products, delivery channels, geographies and the technologies you rely on, then map mitigating controls to arrive at a defensible residual risk position.

The output is a methodology and scoring model you own and can re-run as the business changes, not a one-off document. We make the assumptions explicit so the assessment survives challenge from a supervisor, a correspondent bank or an external auditor, and so it genuinely drives where you focus monitoring, due diligence and resources.

We translate the risk assessment into the written framework that governs how the business operates: AML/CFT policy, sanctions policy, KYC/KYB and customer due diligence procedures, enhanced due diligence and PEP handling, transaction-monitoring and reporting procedures, record-keeping, and the supporting control standards. Documents are written to your licence conditions and applicable regime — typically across EU/EEA, the UK, Switzerland, the UAE and offshore jurisdictions — and to your actual products, not a generic template.

Critically, we write procedures at the level of detail an operator can follow: who does what, on what trigger, to what standard, and with what evidence. A policy that reads well but cannot be executed by your first-line team is the single most common reason frameworks fail in practice, and we design specifically against that.

Policy only becomes operational when it is supported by tooling that fits your flows. We help you specify, select and configure the systems that do the day-to-day work: identity verification and KYC for individuals, KYB and ultimate-beneficial-owner resolution for corporate customers, ongoing due diligence and periodic review, and transaction monitoring tuned to your products and customer risk.

We focus on the parts that determine whether a system works in practice — risk-based onboarding journeys, monitoring rules and thresholds calibrated to your typologies, alert handling and case management, and a defensible audit trail behind every decision. Where you already have vendors in place, we work with your stack; where you do not, we help you choose tooling that is proportionate to your size and risk rather than over-built.

Sanctions exposure carries strict-liability risk and demands controls that are both accurate and demonstrable. We implement screening across customers, beneficial owners, counterparties and, where relevant, payment messages — covering onboarding, ongoing screening against list updates, and real-time checks where your transaction flows require them.

We address the parts that cause real-world failures: list coverage and provenance, matching logic and fuzziness, sensible thresholds to manage false positives, and a documented escalation and resolution path for true matches, potential matches and blocked transactions. The objective is screening you can evidence to a regulator and a correspondent — covering the right lists, at the right points, with every alert resolved and recorded.

Supervisors increasingly judge a framework by its governance: clear accountability, a senior management team that demonstrably oversees AML/CFT, and management information that lets them do so. We define the operating model — board and committee oversight, the role and authority of the MLRO or nominated officer, three-lines-of-defence responsibilities, and escalation routes — and the management information that makes it real.

We build the MI and reporting that turn activity into oversight: alert and case volumes, SLA and backlog metrics, screening and onboarding outcomes, high-risk and PEP exposure, and SAR/STR reporting. The aim is a governance layer where the right people see the right information in time to act, and where that oversight is evidenced — which is exactly what an inspection looks for.

A framework is only as strong as the people executing it. We deliver role-based training so that first-line staff, compliance officers and senior management each understand their specific obligations — not generic awareness slides, but the typologies, red flags, procedures and escalation paths relevant to their actual work.

We build training into the operating rhythm: induction for new joiners, periodic refreshers, targeted sessions when procedures or risks change, and records that evidence completion and competence. Done well, this is what moves compliance from a function people route around to a culture the business runs on — and it is increasingly a control regulators test directly.

We close the loop by making the framework demonstrable. That means a complete control inventory mapped to your obligations, evidence that controls are not just designed but operating, and a state of permanent readiness for internal audit, external audit, a correspondent's due diligence or a supervisory inspection. We can run a pre-audit gap assessment, remediate findings and prepare your team for the questions an examiner will ask.

Implementation is the start, not the end. Frameworks drift as products, volumes and regulations change, so we support ongoing operation — periodic risk-assessment refreshes, control testing and tuning, and updates as the regime evolves. Engagements are scoped to your stage, from standing up a framework for a new licence to strengthening an existing programme, and we can provide ongoing compliance support where you need capacity alongside the framework itself.