What we do

AML & Financial Crime

We support organisations in designing and improving risk-based financial crime frameworks that connect customer risk, controls, data, escalation and management oversight.

When organisations call us

  • It is unclear whether — and to what extent — the organisation is an obliged entity under AML/CFT rules.
  • A new product, channel, market or client group changes the risk profile faster than the controls.
  • Customer or transaction volumes grow without scaling KYC/CDD, screening or monitoring.
  • A regulator, auditor, correspondent bank, investor or partner has raised recommendations.
  • The EU AML package (AMLR/AMLD6/AMLA) requires a structured readiness plan before July 2027.

Questions we help answer

  • Does our risk assessment cover the real business model, products, channels, clients and geography?
  • Are customer risk criteria consistent, explainable and actually applied?
  • Do alerts, escalations and decisions leave an audit trail we can defend?
  • How do we prepare the framework, data and vendors for the AMLR single rulebook?

How we can support

  • Applicability analysis — whether and how AML/CFT obligations attach to your model.
  • Business-wide risk assessment — methodology, execution and management sign-off.
  • Customer risk methodology — segmentation, scoring, EDD triggers and overrides with documented rationale.
  • KYC/CDD and screening design — processes, data model, vendor requirements and quality controls.
  • Transaction monitoring — scenario design, thresholds, tuning governance and alert-handling standards.
  • SAR/STR readiness — internal escalation, decision documentation and reporting workflows.
  • AMLR gap analysis — mapping current policies and tooling to the incoming single rulebook.
  • Independent framework review and remediation — findings, priorities and a plan that closes them.

Typical work products

Risk assessment report, customer risk model documentation, AML policy set, CDD/EDD procedures, screening and monitoring requirements, alert-handling playbooks, MLRO reporting pack, AMLR readiness roadmap, remediation plan with owners and dates.

We support and challenge your framework; statutory roles and filings remain with your appointed officers, and formal legal opinions with qualified counsel.

Insights

Bring clarity to the next decision.

A first conversation is free of charge, confidential and without obligation.

Discuss a challenge