Reduce risk. Strengthen control. Operate with confidence.
Reduce risk. Strengthen control. Operate with confidence.
Subject Persons must comply with AML/CFT and Sanctions requirements under the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) and National Interest (Enabling Powers) Act (NIA). This includes interpreting regulatory expectations, maintaining proportionate controls, documenting decisions, managing supervisory interactions, and demonstrating that their risk-based approach is defensible in practice. The consequences of non-compliance can be regulatory, operational and reputational.
We specialise exclusively in Financial Crime Compliance and provide senior, judgement-led advisory that aligns with how regulators assess obligations in the real world. We translate rules into practical steps, design frameworks that hold up under scrutiny, and support clients through day to day operations, inspections, remediation and supervisory requests with clarity and calm. Our work combines regulatory insight, hands-on implementation and a deep understanding of operational realities, ensuring that your compliance environment is proportionate, structured and trusted.
Subject Persons must appoint a Money Laundering Reporting Officer (MLRO) responsible for overseeing AML/CFT controls, managing internal reporting and liaising with the FIAU. The MLRO plays a central role in assessing suspicions, ensuring timely reporting and maintaining oversight of the compliance framework. In parallel, evolving obligations under the NIA require a structured sanctions framework, including clear governance, oversight and reporting responsibilities, and the appointment of an SCO. Both roles carry significant accountability and require documented, defensible decision‑making and effective operation of controls in practice.
We provide practical, senior‑level support to MLROs and SCOs, helping them navigate complex decisions, maintain oversight and meet regulatory expectations with confidence. We work alongside your appointed officers to strengthen reporting processes, support escalation decisions and reinforce governance across AML/CFT and sanctions compliance. Our involvement brings clarity to complexity, additional capacity and an experienced external perspective, particularly during periods of pressure, regulatory interaction or inspection readiness. The result is a more structured, resilient compliance function, where responsibilities are carried out consistently and decisions are supported by clear rationale and defensible documentation.
Subject Persons must maintain documented AML/CFT and Sanctions policies and procedures that reflect their business model, risk exposure, operational structure and regulatory obligations. These documents must be clear, regularly updated, and applied consistently. They serve as evidence of governance and demonstrate how the firm intends to prevent, detect and respond to financial crime.
We develop policies and procedures that go beyond compliance templates. Our documents are tailored, defensible and grounded in regulatory expectations, ensuring they reflect your actual operations and can withstand supervisory review. We bring clarity to complex obligations and structure your controls, so they are practical to implement, easy to follow and aligned with your risk appetite. For clients using CDDgenie or our CDD Managed Services, ongoing regulatory updates are incorporated seamlessly.
All Subject Persons must identify, assess and document their exposure to financial crime risks, including customer, geographical, service, transactional and delivery channel risks. A Business Risk Assessment is mandatory under both the PMLFTR and the NIA, and must be updated periodically to reflect changes in operations, typologies and regulatory expectations. It forms the foundation of the risk-based approach and influences all controls, decisions and oversight requirements.
We design and implement structured, evidence-based BRA methodologies that are proportionate to your size, complexity and client base. Our approach mirrors how supervisors analyse risk assessments: clear scoring rationale, documented reasoning, defensible classifications and practical recommendations. We bring rigour and clarity to the process, ensuring your BRA is more than a formality and becomes a powerful decision-making and governance tool.
Subject Persons must conduct customer identification, verification, screening, risk assessment and ongoing monitoring in line with the PMLFTR, NIA and FIAU Implementing Procedures. They must maintain complete and auditable files, apply a risk-based approach, document rationale, and ensure enhanced due diligence where required. CDD is mandatory at onboarding and throughout the relationship.
We support CDD through a hybrid advisory-plus-technology model powered by CDDgenie. Our methodology ensures consistent, structured and regulator-aligned due diligence across onboarding, monitoring and remediation. Whether you manage CDD internally (CORE), in partnership with us (ASSURE) or outsource it fully (ASSIST), you gain access to senior judgment, trained local specialists and a defensible risk framework embedded directly into your workflow. We reduce operational burden, strengthen documentation quality and give you confidence that your CDD files will stand up to regulatory scrutiny.
Subject Persons are expected to maintain ongoing oversight of their AML/CFT and Sanctions controls through independent internal reviews. Regulators expect firms to test the effectiveness of their policies, procedures, governance and CDD frameworks, identify deficiencies, and take timely remedial action. Independent audits or health checks are essential to demonstrate sound governance and readiness for inspections.
We conduct independent, regulator-aligned compliance reviews that assess your framework with the same scrutiny applied during supervisory examinations. Our reporting highlights findings clearly, provides actionable recommendations and prioritises remediation in line with regulatory impact. We bring objectivity, sector-specific insight and clarity to your governance environment, helping you eliminate blind spots and strengthen your readiness for inspections and thematic reviews.
Subject Persons must ensure that staff understand their AML/CFT and Sanctions obligations, know how to identify and escalate suspicious activity, and are trained regularly on policies, procedures, red flags and emerging risks. Training is a core requirement of a healthy compliance culture and must be relevant to roles and risk exposure.
We deliver targeted, practical training that blends real-world regulatory insights with operational application. Our sessions are designed to strengthen judgment, not memorisation, ensuring staff understand not only what the rules are but how to apply them in daily work. We tailor content to your sector, risk exposure and internal processes, giving your team the confidence to make defensible decisions and contribute to a strong compliance culture.