The licence is the easy part.
We build what sits behind it.
Black Sea builds, remediates and runs the AML/CFT and sanctions programme behind a licence, for regulated operators across the Gulf, Africa, Central Asia, Turkey and Pakistan. Lawyers file. We build the compliance.
Compliance is no longer a risk to weigh.
It is an exposure to remove.
Across our markets, regulators are setting hard deadlines and naming firms. The quiet window is now, before the queue, before the examiner is already watching.
Three ways in. One next step.
"I need a licence."
You are racing a VASP, CASP, PVARA or DPMS deadline. We build the programme an examiner actually tests, and have it ready before you file.
- New-regime programme build
- Application-ready evidence
- Named MLRO in place
"I've been flagged."
An enforcement action, a supervisory finding, a grey-list wave. We turn it into a clean re-inspection, independent and conflict-free, on a fixed scope.
- Post-enforcement remediation
- Independent reviewer / audit
- Regulator-ready evidence
"I need ongoing cover."
A named, fit-and-proper MLRO, a managed financial-intelligence function, and an annual independent audit, run for you on a retainer.
- Fractional named MLRO
- Managed FIU / monitoring ops
- Independent annual audit
We work with specific
types of problems.
- You are racing a new-regime deadline (VASP, CASP, PVARA, DPMS) and need the programme an examiner will actually test.
- You have been named in an enforcement action or caught in a grey-list wave and need independent, conflict-free remediation, fast.
- You hold a licence (VARA, ADGM, AFSA, SEC, CBB) and are not certain your AML programme would survive a supervisory visit.
- You need a named, fit-and-proper MLRO on a fractional, retained basis.
- You have a defined problem, multi-jurisdiction AML, UBO complexity, the Travel Rule, sanctions or export-control, and want it solved at fixed scope.
- You are a law firm or fund administrator whose client needs the compliance built behind the licence.
For matters that need a signed legal opinion we work alongside partner counsel, we are not the law firm. We scope properly rather than race to the cheapest tick-box, we screen UBO and sanctions before we engage, and we say no when we should.
Diagnostic first.
Everything starts here.
- A 30-minute call describing what you are trying to license, fix or run
- Basic information on your entity, jurisdiction and current status
- Any existing regulatory correspondence or licences
- No preparation required beyond that
- A written gap report against the applicable framework
- A prioritised remediation list with clear next actions
- A scope and timeline for what a full engagement involves
- An honest assessment of whether one is needed
- Operators racing a new-regime licensing deadline
- Firms named in an enforcement action or grey-list wave
- Licence-holders before a supervisory visit or audit
- Any operator who suspects a gap but cannot place it
Build it. Run it. Defend it.
One core engine, the programme an examiner actually tests, delivered across the work that matters: the build, the ongoing operation, and the higher-risk sanctions lane.
The AML/CFT programme
The programme behind a licence, for a new-regime application or a post-enforcement fix.
- Business risk assessment
- CDD, EDD & screening
- Transaction monitoring & Travel Rule
- FIU & goAML reporting
Outsourced MLRO, FIU & audit
The function operated for you, named and fit-and-proper, on a retainer.
- Fractional named MLRO
- Managed FIU / 1LoD operations
- Independent annual audit
- Model validation & QA
Sanctions & export-control
Integrity diligence for the higher-risk lanes, including defense and dual-use.
- Sanctions-exposure screening
- End-user & intermediary diligence
- Anti-bribery & corruption controls
- Defense & dual-use review
Every obliged sector, one engine.
The regulator and the risk flavour change. The programme underneath does not. We build it across nine verticals.
Environments others won't
touch with a shovel.
Nineteen active markets across the Gulf, Africa, Central Asia, Turkey and Pakistan, where the framework is forming in real time and the deadline is real.
Three problems, solved properly.
Operator-side.
Not consultancy-side.
We've sat the seat
Our people have built and run regulated structures. The advice is what we would have wanted when we were on the other side of the table.
Clear scope, no hourly billing
A diagnostic in two weeks, full mandates scoped up front. Hourly billing creates the wrong incentives, so we do not use it.
Lawyers file, we build
For matters that need a regulated legal opinion we work alongside partner counsel. We are the compliance specialist, not the law firm.
The licence is the easy part. We write the rest.
All briefings →Tell us where you are.
We'll send a costed plan in 48 hours.
Most engagements start with a 30-minute call. We review what you are trying to license, fix or run, tell you honestly whether we can help, and what it would look like if we did.