6
Distinct load factors
19
Markets served
5
Service lines
100%
Operator-side
02The operating reality
02
Banks and financial institutions sit at the centre of the payment system. Commercial and retail banks, microfinance and mortgage houses, non-bank finance companies, leasing and factoring firms and credit providers all take deposits or extend credit, hold customer funds, and move value across borders. Every one of those functions is a channel a launderer, a sanctioned party or a proliferation network will try to use.
The load is not a form. It is a continuous obligation that does not pause between examinations.
The obligations in full
- Customer due diligence and beneficial-ownership identification at onboarding, and again when risk changes.
- Ongoing transaction monitoring calibrated to the customer base, not bought off a shelf.
- Sanctions and watchlist screening at onboarding, at payment, and live as lists change.
- Correspondent banking and nested-relationship risk: exposure inherited from counterparties you never onboarded.
- Politically exposed person handling, trade-finance and dual-use goods risk.
- Suspicious-transaction reporting to the national financial-intelligence unit, on time and to standard.
- Board and senior-management accountability, with a named officer who carries personal responsibility.
When it fails, it fails publicly: a supervisory finding, a remediation order, a fine, a de-risked correspondent line, a franchise put at risk.
R/01
Continuous CDD
Due diligence and beneficial ownership at onboarding, and again when risk changes.
R/02
Monitoring that fits
Rules calibrated to the customer base, not bought off a shelf.
R/03
Screening at payment
Sanctions and watchlists at onboarding, at payment, live as lists change.
R/04
Correspondent risk
Nested relationships: exposure inherited from counterparties never onboarded.
R/05
PEP and trade finance
Politically exposed persons, trade-finance and dual-use goods risk.
R/06
Named accountability
Board oversight, with an officer who carries personal responsibility.
03The examination surface
What the examiner tests
A banking supervisor does not test whether you have a policy. It tests whether the programme runs, whether it matches your actual risk, and whether it holds up when it is used in anger. For a bank or FI, the examiner looks at:
01
Risk assessment. Is there a documented, current enterprise-wide money-laundering and terrorist-financing risk assessment, and does the rest of the programme flow from it, or contradict it?
02
CDD and beneficial ownership. Are customers identified and verified to standard, are ultimate beneficial owners established, and is enhanced due diligence applied where risk demands it?
03
Transaction monitoring. Are the rules and thresholds tuned to this customer base? Are alerts worked, dispositioned and evidenced, or is there an unmanaged backlog?
04
Sanctions screening. Is screening applied at onboarding and at payment, against current lists, with defensible fuzzy-matching and a documented disposition trail for hits?
05
Correspondent and cross-border risk. Are correspondent relationships risk-rated, are nested and downstream relationships understood, and is the Travel Rule handled where it applies?
06
Suspicious-transaction reporting. Are STRs and SARs identified, escalated and filed with the national FIU on time, and is the decision not to report also evidenced?
07
The MLRO and governance. Is there a named, competent and empowered money-laundering reporting officer, with a reporting line to the board and the authority to act?
08
Independent testing. Has the programme been independently audited, and were the findings closed rather than logged and left?
An examiner does not grade intentions. It grades what runs.
04The work
We map to five service lines. For a bank or FI they read as follows. Each is a fixed scope and a fixed fee, with no hourly billing.
S/01
Licensing and new-regime programme build
The lawyer files. We build the compliance.
For a new bank, finance company or FI entering a regime, or an operator moving markets, we build the AML and sanctions programme the supervisor expects behind the licence: risk assessment, policies, CDD and screening framework, monitoring model, MLRO function and reporting lines.
S/02
Remediation
The programme after the finding.
After a supervisory finding, an enforcement action or a failed audit, we run the remediation: root-cause analysis, lookback and file remediation, control redesign, and a closure programme evidenced to the standard the regulator asked for.
S/03
Outsourced and bridge MLRO, plus a managed FIU function
A named officer and a working reporting line.
Where a named officer is required and you do not yet have one, or you have lost one, we provide an outsourced or bridge MLRO and can run the day-to-day financial-intelligence function: alert handling, escalation, and STR preparation and filing.
S/04
Independent AML audit
The reviewer, not the seller.
We perform the independent AML audit a bank or FI needs for its board and its supervisor, and we test the programme as an examiner would. Because we sell no software and take no commissions, nothing we earn depends on the answer.
S/05
Sanctions, export-control and integrity due diligence
Screening that holds, including the Travel Rule.
We build and stress the sanctions and export-control controls, including correspondent and dual-use exposure and the FATF Travel Rule, and run integrity due diligence on counterparties and relationships.
INDEPENDENT · CONFLICT-FREE · SENIOR-ONLY · NO SOFTWARE · NO COMMISSIONS
05Cross-market / 19 theatres
Across all 19 markets
Banks and FIs are supervised in every one of our nineteen markets. The supervisor and the register change; the obligation does not. We build to the body that will actually examine you. A few anchors from the verified regulator map:
UAE
The Central Bank of the UAE (CBUAE) for onshore licensed financial institutions, with the ADGM FSRA and the DIFC DFSA for the two financial free zones.
Saudi Arabia
SAMA, the Saudi Central Bank.
Turkey
The Banking Regulation and Supervision Agency (BRSA / BDDK) for prudential supervision, with MASAK, the Financial Crimes Investigation Board, on the AML side.
Kazakhstan
The Agency for Regulation and Development of the Financial Market (ARDFM) for the national regime, with the Astana Financial Services Authority (AFSA) for the AIFC banking regime.
South Africa
The Prudential Authority within the South African Reserve Bank, with the National Credit Regulator (NCR) and the Financial Sector Conduct Authority (FSCA) on the credit and conduct side.
Pakistan
The State Bank of Pakistan (SBP) for banks, with the SECP for non-bank lenders, finance companies, leasing and factoring.
Egypt
The Central Bank of Egypt (CBE), with the Financial Regulatory Authority (FRA) for non-bank financial activity.
Qatar
Qatar Central Bank (QCB) onshore, with the QFCRA and QFCA in the Qatar Financial Centre.
Elsewhere
Azerbaijan (CBAR), Bahrain (CBB), Georgia (NBG), Ghana (BoG), Jordan (CBJ), Kenya (CBK), Kuwait (Central Bank of Kuwait), Kyrgyzstan (NBKR), Nigeria (CBN), Oman (CBO) and Uzbekistan (CBU).
Every market listed is fully and equally served. No market is a flagship. The current framework in each market is confirmed against the named supervisor before we scope.
06Scope limits, stated plainly
Where the supervision splits
Banking and finance are not regulated identically across these markets, and we say so before you engage. In several markets, deposit-taking and lending sit under more than one authority, and the regime you are actually in determines the programme.
Two authorities
In Pakistan, banks answer to the State Bank of Pakistan while non-bank lenders, leasing, factoring and finance companies answer to the SECP. In Egypt, banking sits with the Central Bank while non-bank financial activity sits with the FRA. In South Africa, prudential, credit and conduct supervision are split across three bodies. We build to the correct combination, not to a single assumed regulator.
Free zones
In the Gulf financial free zones (ADGM, DIFC, the QFC), a bank or FI is supervised by the zone authority (FSRA, DFSA, QFCRA) and not by the onshore central bank. We confirm which regime applies before scoping.
Not permitted
Some activities a client assumes are "banking" are, in a given market, licensed elsewhere or not permitted at all for the entity type in question. Where that is the case we tell you, and we do not build a programme for a permission that does not exist.
We verify first
The licensing position is checked against the named regulator before we scope.
We would rather lose a scope than build the wrong one.
07Market x sector
The sector page tells you what we build. The market pages tell you who examines it. A handful of the Banks & FIs combinations:
Banks & FIs inUAE
Banks & FIs inSaudi Arabia
Banks & FIs inTurkey
Banks & FIs inKazakhstan
Banks & FIs inNigeria
Banks & FIs inSouth Africa
Banks & FIs inEgypt
Banks & FIs inPakistan
Or go straight to the market. All nineteen, evenly served:
AzerbaijanCBAR
BahrainCBB
EgyptCBE · FRA
GeorgiaNBG
GhanaBoG
JordanCBJ
KazakhstanARDFM · AFSA
KenyaCBK
KuwaitCENTRAL BANK OF KUWAIT
KyrgyzstanNBKR
NigeriaCBN
OmanCBO
PakistanSBP · SECP
QatarQCB · QFCRA
Saudi ArabiaSAMA
South AfricaPA (SARB) · NCR · FSCA
TurkeyBRSA / BDDK · MASAK
UAECBUAE · FSRA · DFSA
UzbekistanCBU
08Proof
Published workBriefing seriesA standing series on frontier and Gulf financial-crime regulation, including banking and FI supervision, current and dated, with independent Kazakh press pickups.Insights →
CredentialsCAMS / ICACredentialed practitioners, with front-line KYC and financial-intelligence experience on the team.The firm →
Fresh proofVerifiable todayCurrent dated evidence rather than client references. No published client names, no invented case studies.The record →
The licence is the easy part. We build what sits behind it.
Send the regime, the entity and the position you are in. Costed plan within 48 hours. Fixed scope. No hourly billing.
operations@blackseaspv.com · · CONFIDENTIAL · OPERATIONAL