Anti-money laundering, sanctions, transaction monitoring and the MLRO function, designed around the firm’s customers, products and corridors, and defended before the regulator.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
A financial crime framework earns the licence, keeps the bank account and passes the regulator’s review. We design, build and test the framework for payment, e-money, remittance, cryptoasset and gaming firms, from the business-wide risk assessment to the rules in the monitoring system and the reports that reach the board.
Every control is written for the firm’s own customer base and corridors. A remittance business serving one corridor and a stablecoin issuer serving institutions carry different risks, and their frameworks say so.
The assessment regulators expect to see first: customers, products, geographies, channels and delivery, scored and refreshed annually.
Onboarding, enhanced due diligence, politically exposed persons, beneficial ownership and ongoing review, with the provider stack configured to the policy.
Rules, thresholds and typologies tuned to the firm’s flows, with alert handling, investigation standards and tuning records.
Screening at onboarding and in payment flows, list management, fuzzy-match calibration and escalation.
Suspicious activity reporting, the annual MLRO report, training and the records the regulator asks for in a visit.
Independent testing of the framework, with findings prioritised and tracked to closure.
| Deliverable | What it contains | Who relies on it |
|---|---|---|
| Business-wide risk assessment | Methodology, scoring, inherent and residual risk by category, board sign-off | Board, regulator, banks |
| AML and sanctions policy set | Policies, procedures, customer risk model, EDD triggers, screening standards | Staff, auditors, regulator |
| Monitoring design | Rules library, thresholds, typologies, alert workflow, tuning records | MLRO, auditors |
| MLRO annual report | Framework effectiveness, SAR statistics, training, changes and recommendations | Board, regulator |
| Independent test report | Findings, severity, owner and remediation plan | Board, audit committee, banks |
Yes. Banks and payment providers review the business-wide risk assessment, the policies and the monitoring design as part of their onboarding. A framework prepared to this standard shortens that review.
The framework is system-independent. We configure the rules and screening settings in whichever provider the firm uses, and advise on selection where a provider has yet to be chosen.
The MLRO is an approved role held by the firm’s own officer. We prepare and support that person and provide interim cover where the regulator permits it.
Annually, and whenever the firm adds a product, a market or a material customer segment.
Yes, including blockchain analytics, travel-rule compliance and the typologies specific to exchanges, custodians and issuers.
A reply within three business hours and a written proposal on scope, cost and timing the same day.