AML programme design
Business-wide risk assessment, policy, procedure and a control set that maps to how your firm actually operates.
London · AML & KYC advisory
Controls that hold up when the file is pulled.
We build anti-money-laundering and know-your-customer frameworks for regulated firms — proportionate enough to run every day, and documented well enough to defend under inspection.
Case ledgerIllustrative
IB-4471
Corporate onboarding3 beneficial owners verified
Screening
IB-4472
Politically exposed personEnhanced due diligence requested
Screening
IB-4473
Sanctions matchReferred to the MLRO same day
Screening
IB-4474
Periodic reviewLow risk, next review in 36 months
Screening
IB-4475
Adverse mediaOne article, relevance assessed
Screening
Sample records. No client data is shown on this page.
Coverage
London · head office
Frankfurt
Dubai
Singapore
New York
Remote engagements worldwide
Services
Bespoke work, not a template programme
Every engagement starts from your business model, customer base and risk appetite. The list below is where most work begins — it is not the limit of what we take on.
KYC and due diligence
Customer due diligence, enhanced due diligence, beneficial ownership and source-of-funds testing built into onboarding.
Sanctions and watchlists
List selection, threshold calibration, alert handling and the evidence trail behind every disposition.
File remediation and look-backs
Back-book reviews at volume, with a defined quality bar, sampling method and reporting the regulator can follow.
MLRO and board support
Interim and outsourced MLRO cover, management information, annual reporting and preparation for supervisory visits.
Training and testing
Role-specific training for front office and operations, plus independent testing of whether controls work in practice.
Approach
Four phases, in order
Each phase produces something you can put in front of a regulator. We do not move on until it exists.
Phase 01
Diagnostic
Gap analysis against the Money Laundering Regulations, JMLSG guidance and current supervisory focus.
Phase 02
Design
Risk assessment refreshed, policy and procedure rewritten, roles and escalation routes agreed in writing.
Phase 03
Implementation
Screening tuned, workflows changed, staff trained, and the first live cases worked alongside your team.
Phase 04
Assurance
Independent testing, management information for the board, and a remediation plan for anything that fails.
We work to
MLR 2017
FCA Handbook
JMLSG
6AMLD
FATF Recommendations
OFSI
OFAC
Wolfsberg
Contact
Tell us what is being tested
A supervisory visit, a new product, a back-book that has drifted, or an auditor's finding you need closed. Send the outline and we will tell you what the work looks like and what it costs.
- Head office
- London, United Kingdom
- Funders
- Sign in to the funder portal