AML/CFT and sanctions advisory for regulated firms worldwide
Deepest in frontier markets and the Gulf. We build, repair, staff and test the financial crime programmes that supervisors examine.
What sits behind the licence
The licence is the easy part. We build what sits behind it.
That is the programme a supervisor examines: the business risk assessment, policies and procedures, customer due diligence, screening and monitoring rules, reporting to the FIU, training, the MLRO's reports and the board pack.
Black Sea is an advisory firm and sells no software. Your systems stay your own, and we write the rules and tests they have to meet.
Where our engagements begin
Each service starts from a moment like one of these.
| The moment | The service |
|---|---|
| You are applying for a licence, or a new law brings you into scope | Licensing & new-regime build |
| A supervisor, auditor or correspondent bank has found gaps, with a deadline | Remediation |
| Your MLRO is leaving, or a new licence needs one at launch | MLRO cover & ongoing support |
| Your rulebook calls for an independent review, or your board wants one | Independent AML audit |
| A counterparty, owner or shipment needs clearing before you proceed | Sanctions & integrity DD |
| A bank or payment partner asks questions your programme cannot yet answer | Bank & partner onboarding |
| A new product, market or activity may change who supervises you | Product & perimeter review |
Why firms bring us in
Written to your rulebook
Each programme is written against the rulebook your supervisor examines, for your licence category and your market. A virtual asset firm in Dubai outside the DIFC answers to VARA, and one inside the DIFC answers to the DFSA, so their programmes are written to different texts.
One fixed fee per stage
You commit to one stage at a time. The costed plan states the fee for each stage, what it includes and what it leaves out.
Independent of your team and your vendors
We sell only our own work, so a finding of ours is never a sales lead. We never audit a programme we built or run.
Senior practitioners, with law firms in market
The practitioners who scope your work deliver it. Where a point turns on local law, a law firm in your market advises under its own engagement.
How an engagement runs
| Stage | When | What you hold at the end |
|---|---|---|
| Assess | Weeks 1 and 2 | A written gap report against your rulebook, and a fixed fee for the build |
| Build | Weeks 3 to 8 | The documents, rules and training the report found missing, in place and approved by your management |
| Operate | From go-live | Officer cover, ongoing support and periodic testing, monthly |
The costed plan sets the actual weeks. If you go ahead with the build, the assessment fee is credited against it, on the terms the plan states.
An audit, a diligence file or a perimeter review runs as one stage, at one fixed fee.
Worldwide, deepest in frontier markets and the Gulf
We work worldwide. Nineteen markets in five regions are mapped in depth, each in a section on who supervises which licence and under which text.
Get a costed plan
Tell us the market, the licence and what has happened. A senior practitioner replies with a costed plan within 48 hours of your message.
If the detail needs an NDA, we send ours first. We never publish client names.