What this area covers: AML program development in the US
AML program development is one of 6 parts of our “Compliance & AML” practice. It covers the full cycle from initial scoping to operational launch, run by a single named partner from our US practice.
What it is in the US: policies · procedures · control mechanisms.
How we handle AML program development
The “AML program development” project in the US is structured as a 4-stage process run by a single named partner.
FinCEN reporting, the beneficial-ownership (BOI) rules for foreign entities registered in the US, OFAC sanctions screening and AML programme drafting.
The same desk that runs AML program development handles your banking, bookkeeping, compliance and — where needed — your wind-down.INNOVA · Operating model
Why the United States
The largest market, deep capital, a choice of state (Delaware, Wyoming, Florida), and a straightforward registration process. We use it for operating companies, reaching US investors, and structures built for venture funding.
A reliable regulatory environment
Banking ecosystem
Corporate tax 21% federal + state taxes
Local execution, one plan
Why INNOVA
What changes for you when INNOVA runs the project. If a company or a second jurisdiction is not needed yet, we will say so plainly.
Turnkey, without the extra hassle
One window and one contract: we take the task whole, handle everything on your behalf with our own team and trusted contractors, and you buy the result. From you we need decisions and signatures; we get in touch only when the next step depends on you.
We handle banks and regulators
A bank refusal, a registry query, a regulator's request, a stalled deadline: we answer, rework the file and resubmit at no extra charge for our work until the matter is closed.
We see it through
The partner who opens your project carries it through to the result, even when the process runs for months, and stays on afterwards: renewals, filings, changes to the structure. Where the law requires a licensed professional, we bring one in and remain answerable to you.
A boutique, personally involved
We have worked in international business since 2012. An experienced partner runs your project personally, and unusual structures are our field: where you hear “that can't be done”, we look for the lawful route.
Your affairs stay yours
Information about you, your structure, your beneficial owners and your deals reaches neither competitors nor third parties. Banks, registries and regulators receive exactly what the law or the procedure requires, and the contract says so.
Faster and more precise
We build the file around the specific bank's and regulator's requirements before filing. Experience means we get the work right straight away, where some firms need three attempts. A partner replies in writing within 24 hours.
How the work is structured
A 4-stage process led by a single named partner — from scoping to the operational hand-over.
Risk assessment
Risk assessment across products, clients and geography
Program development
Manuals, training and control mechanisms
Regulator submission
Submission of the documentation to the regulator
Monitoring
Reviews, audits and keeping the program current
What we need from you · what you get from us
What we need from you to begin — and what you walk away with. We won't pester you with needless questions: we already have most of the answers.
- Activity / sector descriptionstructured
- Customer-base profiledocumented
- Geographic exposuremapped
- Existing controls (if any)stated
- AML/CFT risk assessmentregulator-ready
- Compliance manual + proceduresoperational
- MLRO appointednamed officer
- Training programme (annual)delivered
- Customer DD templatesready to use
- Sanctions/PEP screening liveautomated
Four ways to work together
We don't quote a fixed price without understanding your situation — cost depends on the complexity of your case. Send a written request or book a paid consultation, then we pick the right format.
Consultation
A paid 30-minute video consultation with a partner. We discuss your situation, define the project scope, and propose a structure and timeline.
Written analysis
A written consultation with a full review of the business — tax positioning, structure options, jurisdiction comparison, banking path. Turnaround: 5 business days.
Operating roadmap
For complex situations — multi-jurisdiction structures, regulated activity, founder relocation. A full plan with stages, dependencies, deliverables and timing.
Direct execution
You know what you need — we execute. No advisory mark-up and no discovery phase.
Fill in the questionnaire
Complete the online questionnaire: a partner studies your case and replies in writing within 24 hours.
Fill in the questionnaire
4 steps · a partner replies in writing within 24 hours.
A partner reads the questionnaire, replies in writing at the email you gave within 24 hours, then a written quote follows. Work starts after you accept it.
Frequently asked questions
The questions we're asked most often. If yours isn't here, a written request is the fastest way to get an answer.
Most “AML program development” projects in the United States run 4–5 weeks start to finish. The fastest stage is document filing; the longest is post-registration onboarding (banking, tax registration). A single named partner runs the project throughout.
From US$ 6,500 · program development. The lower bound is for clean, standard profiles; the upper bound is for complex ownership structures, multi-jurisdiction projects or regulated activity. A fixed quote follows once we have scoped the task.
In most cases, no. The entire process runs remotely under a notarised power of attorney. A handful of jurisdictions require an in-person visit (typically biometrics for a residence permit) — we plan those as efficiently as possible.
Beneficial Ownership Information (BOI) reporting flows from the Corporate Transparency Act (CTA), but FinCEN's interim final rule of March 26, 2025 sharply narrowed who files: companies formed under any US state law are now fully exempt. The obligation stays with foreign-formed entities registered to do business in a US state. They report to FinCEN the beneficial owners — 25%+ ownership or substantial control — who are non-US persons; US-person owners are not disclosed, and a foreign entity owned entirely by US persons is exempt. Those registered before March 26, 2025 filed by April 25, 2025; later ones have 30 days from when their registration takes effect. Willful non-compliance: $500/day in civil penalty and up to 2 years imprisonment.
Under the CTA, a beneficial owner is an individual who either (1) directly or indirectly owns or controls 25% or more of the company's ownership interests, or (2) exercises substantial control over the company (CEO, CFO, COO, general counsel, or anyone empowered to appoint or remove senior officers or make major decisions). There is no dollar threshold — a 25% LLC member must be reported. Minors, nominees, and certain intermediaries are excluded.
For each beneficial owner: full legal name, date of birth, residential address (not a PO box), and a unique number from a government-issued ID (passport, driver's license) plus an image of that document. The same goes for the company applicant, the person who filed the formation documents. FinCEN issues each beneficial owner a FinCEN identifier: on later filings it replaces re-submitting the full information.
AML program development in other countries
The same service — in every jurisdiction we run. One desk, one standard.
