02Editorial position
We are the reviewer, not the seller.
Most compliance commentary sells a licence, a tool, a jurisdiction. We build and run the programme behind the licence, and write from inside the work.
Getting the licence is the part everyone plans for. Keeping it, through an inspection or an enforcement action, decides who survives.
Lawyers file. We build the compliance.
03Series 001
Running series · AML/CFT programme build
The licence is the easy part
The anchor series
Each entry walks one regime from licence condition to working programme. The application says the programme exists; the inspection asks it to work.
/What the framework actually requires.
/Where operators fall short, from the field.
/What "good" looks like when a regulator tests it.
/How to sequence a build so nothing is left to the inspection.
04Regime explainers
One regime. Read start to finish.
Explainers map a single regime end to end, so you see the whole obligation before committing capital. Grounded in the current published framework.
Explainers by sectorBy business modelHow the obligation reads for your business model across all 19 markets: VASP, payments, banks, funds, CSP.Browse sectors →
Explainers by marketBy jurisdictionHow one jurisdiction's regime works, and who supervises it. Frontier and Gulf, evenly covered.Browse markets →
Controls / cross-cuttingWhat travels everywhereThe controls across every regime: sanctions screening, the FATF Travel Rule, independent audit, the bridge MLRO function.See what we do →
05Radar / exposure
The framework moved. Here is who it moved on.
Radar is the time-sensitive edge of the series. When a regime opens or an FATF evaluation lands, we write who is exposed and how long they have to act.
06Latest briefings
Live feed · renders from the Substack RSS at build
Series 001The licence is the easy part: why the programme, not the permit, survives the inspection.Read ↗
MLROThe outsourced MLRO, done properly: what a bridge function must actually carry.Read ↗
VASP / CryptoVASP regimes across the Gulf and frontier: reading the obligation before you commit capital.Read ↗
Travel RuleThe FATF Travel Rule, in the markets that are actually enforcing it.Read ↗
RemediationPost-enforcement remediation: how to close a finding so it stays closed.Read ↗
AuditIndependent AML audit: what a real test looks for, and what a rubber stamp misses.Read ↗
07Subscribe
Read the record before the regulator writes it.
Regime changes, remediation lessons, and the Radar calls on who is exposed now. Written for operators and the officers who answer for them.
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08On the record
Independent pickup in the Kazakh business pressCAMS / ICALicensed local law-firm and compliance partners in our markets
The proof is the feed itself: a dated briefing series, independent pickup in the Kazakh business press, and licensed local law-firm and compliance partners in our markets.
The reading is free. The programme is the work.
If a briefing raises a question about your programme, we scope the answer, not sell it: a costed plan within 48 hours.