Compliance & AML

A designated compliance officer (MLRO), a risk assessment, written policies and procedures, a training program, a schedule for periodic effectiveness reviews, and KYC and suspicious-transaction reporting procedures. It is a working program, not a folder of documents assembled for show.

No — that is a common mistake that leads to conditions or refusal. The regulator reviews the licence application together with the AML/CFT program, the appointed MLRO and the KYC procedures. We therefore develop the compliance program alongside the application, not after it.

A correctly described activity, a realistic risk assessment fitted to the specific model, and procedures the company can actually operate. We prepare the pack the way regulators genuinely read applications, avoiding the typical bounce-backs and follow-up queries.

Regulators require a designated compliance officer — this can be an employee or an outsourced MLRO, depending on the jurisdiction and the scale. We help determine the right model and, where needed, support the function at launch.

The program is reviewed when the activity changes, when entering new markets, or when regulatory requirements shift, plus a scheduled effectiveness review (mandatory in several jurisdictions — biennial, for example). We run these cycles so the program stays current.