Services for firms that answer to a supervisor
Each of the seven services starts from a defined moment and ends in a written deliverable, at one fixed fee per stage. Each block below is a scope you can forward to your team.
Licensing & new-regime build
The AML/CFT and sanctions programme your application needs, in place before the supervisor asks for it.
- For: firms applying for a licence or a registration, entering a new market, or brought into scope by a new law.
- When: before the application is filed, or when a new regime sets its start date.
- You receive: the business risk assessment; AML/CFT and sanctions policies and procedures mapped to your rulebook; customer risk scoring and due diligence procedures; screening and transaction monitoring rules; for virtual asset firms, the travel rule procedure; the MLRO framework and reporting lines; record keeping; staff and board training; registration with the FIU's reporting system, on goAML where the FIU uses it.
- Time: about eight weeks from the start of the assessment. The costed plan sets the dates.
- How it starts: an assessment of what you hold against what your rulebook asks for.
- Stays with your law firm: the application itself, legal opinions and representation before the regulator.
Remediation
The repair a finding requires, closed with evidence the supervisor can test.
- For: firms with a finding from a supervisor, an external auditor or a correspondent bank.
- When: after an inspection report, a supervisory letter, a qualified audit or a bank's remediation request, usually with a deadline.
- You receive: a gap analysis against each finding; a remediation plan with owners and dates; rebuilt controls, policies and procedures; look-back reviews where the finding calls for one; an evidence pack for each finding, ready for the supervisor's follow-up.
- Time: worked back from the deadline in the finding. The costed plan shows each date against it.
- How it starts: you send the finding under NDA, and we reply with a costed plan.
- Stays with you and your counsel: correspondence and representation before the supervisor. We prepare the evidence you submit.
MLRO cover & ongoing support
An officer in the seat, or a senior practitioner behind the officer you appoint.
- For: firms whose MLRO is leaving or has left, new licensees that need an officer at launch, and officers who need a second senior reviewer.
- When: a resignation, a licence about to be granted, or a supervisor questioning the capacity of the function.
| Route | What it means |
|---|---|
| Interim officer | A practitioner from us holds the MLRO post for an agreed period, where the rules of your market allow an outside officer. |
| Bridge | Your own appointee holds the post and we stand behind that person on cases, reports and decisions, until the function runs without us. |
| Officer search | We write the role against your rulebook, find and vet candidates, and prepare the appointment file for the one you choose. |
| Ongoing support | After go-live, monthly: alert and case review, suspicious transaction reports drafted for the officer's decision, rule changes, training and the MLRO's reports to the board. |
- You receive: a documented trail of every case and decision, the MLRO's reports to senior management and the board, and a handover file when the engagement ends.
- Time: interim and bridge cover run month by month, for as long as the gap lasts. A search runs up to the approval of the appointment, where your market requires one.
- How it starts: tell us the date the seat becomes empty, or the launch date.
- Stays with you: responsibility for the programme stays with your board. The officer reports to senior management and has direct access to your records.
Where the rules of your market reserve the post for a citizen, a resident or your own employee, your appointee holds it and we stand behind that person.
Independent AML audit
A test of whether your programme works in practice, reported to your board.
- For: boards and audit committees, firms whose rulebook calls for a periodic independent review, and investors assessing a target.
- When: the review falls due under your rulebook, a supervisor or a bank asks for one, an inspection is coming, or a transaction needs it.
- You receive: testing of the programme's design and of how it operates on a sample of real files; screening and monitoring tests; a governance review; a board report with rated findings and a dated action list.
- Time: set by the size of the file sample and the date your report is due. The costed plan fixes the report date.
- How it starts: send the rule or the request that calls for the review, and the last report if there is one.
- Independence: we do not audit a programme we built or run, and we sell none of the systems we test.
Sanctions & integrity DD
A sourced view of who you are dealing with, before you commit.
- For: firms onboarding a high-risk counterparty, clearing a payment corridor or a shipment, and investors or acquirers.
- When: before onboarding, a transaction or a shipment, or when your first line cannot resolve a screening match.
- You receive: ownership traced to the natural persons behind it; sanctions and export control exposure; adverse media and integrity findings; a written risk conclusion with its sources.
- Time: per file, stated in the costed plan.
- How it starts: the name of the counterparty and the decision you need to make, under NDA.
- Stays with your counsel: legal opinions on sanctions law.
Bank & partner onboarding
A programme file ready for the due diligence of a bank or payment partner.
- For: firms opening a bank account, a payment rail, a correspondent relationship or a partnership with a regulated provider.
- When: the bank or partner sends a due diligence questionnaire, asks for your programme documents, or pauses onboarding until it has answers.
- You receive: the questionnaire answered with evidence; the documents the partner asks for, brought to the standard it applies; a review pack with your policy, risk assessment, procedures, screening and monitoring set-up, officer details and latest audit; preparation for the partner's calls.
- Time: set by the partner's deadline. The costed plan works back from it.
- How it starts: send the questionnaire or the partner's request.
- Stays with the partner: the decision. We make sure the file it decides on is complete and accurate.
Product & perimeter review
A written answer on which rules a product or activity brings you under, before you launch it.
- For: firms launching a product, adding an activity or entering a market, and firms unsure whether an activity is in scope at all.
- When: before launch, before a new market, or when a partner or supervisor asks whether an activity is covered.
- You receive: a perimeter analysis by market, naming the rules and the supervisor that apply; the product's financial crime risk assessment; the controls it needs before launch; the questions to put to counsel where the answer needs a legal opinion.
- Time: per product, stated in the costed plan.
- How it starts: a description of the product and the markets where you will offer it.
- Stays with a law firm: a formal legal opinion on the perimeter.
How we work
A build or a remediation runs in three stages, and you commit to one stage at a time. An audit, a diligence file or a perimeter review runs as one stage, at one fixed fee.
| 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.
How the fee is set
One fixed fee for each stage, stated in the costed plan with what it includes and what it leaves out. We do not bill by the hour, and any change of scope is agreed in writing before work on it starts.
Why an outside firm
Your team runs the programme every day, and a review of that work is independent only when someone else carries it out. A build, or cover for an empty seat, also takes hours your team needs for its own work. We take that work off the team and hand it back finished.
Ways to engage
- A project with a fixed end: a build, a remediation, an audit or a diligence file.
- A practitioner beside your team on a defined gap, while your officer keeps the function.
- A standing function under your board: officer cover or ongoing support, monthly.
What we need from you
An NDA, a clear account of your licence stage and of any finding or deadline, access to your documents and people once the NDA is signed, and one person who can approve the scope.
Who does the work
The practitioners who scope your work deliver it, from the assessment to the handover.
Confidentiality
We sign an NDA before you send detail. We never publish client names, and one client's file is never another client's reference.
Get a costed plan
Tell us the service, the market and what has happened. The costed plan sets out the stages, the weeks and one fixed fee for each.