Risk-based AML framework design, KYC policy architecture, MLRo advisory, and financial crime programme documentation for regulated and pre-regulated fintech and digital asset businesses. We build programmes that satisfy FCA supervisory review, and work operationally in the business, not just on paper.
The BWRA is the foundation of every compliant AML programme and mandatory under MLRs 2017 Regulation 18. We conduct and document a risk assessment specific to your business model, products, customer types, geographies, and channels, not a generic template adapted with your firm name.
A complete AML/CTF policy suite, board-approved, specific to your business model, and aligned to MLRs 2017, FCA JMLSG guidance, and MiCA/AMLD6 where applicable. Every policy is written to be implemented, not filed.
Independent assessment of your existing AML/KYC framework against current regulatory requirements, MLRs 2017, FCA JMLSG, and FATF Recommendation 16 (Travel Rule). Output: a prioritised remediation plan with clear timelines and board-ready reporting.
The MLRo function is consistently under-resourced in digital asset businesses. We advise on MLRo function design, provide template board reporting structures, review SAR submission processes, and offer on-call support for complex cases requiring senior financial crime judgment.
The UK Cryptoasset Travel Rule has been in force since September 2023. The FCA has begun active compliance review. We design Travel Rule compliance frameworks, VASP-to-VASP information transmission, counterparty verification, and unhosted wallet risk management.
Digital asset businesses face a specific and evolving fraud risk landscape. We conduct fraud risk assessments covering the typologies that matter for your business model, APP fraud, account takeover, mule activity, scams, card fraud, and on-chain fraud specific to crypto exchanges and custody services.
We review existing AML/KYC documentation, controls, and operations against regulatory requirements. Establishes the baseline and identifies gaps before we begin building.
We conduct the BWRA, specific to your business model, products, and customer profile. This drives the risk-based calibration of every subsequent policy and control.
We design and document the full AML/KYC framework, policies, procedures, CDD standards, transaction monitoring calibration, Travel Rule controls, and MLRo governance.
We support the implementation, board approval, staff training briefings, RegTech vendor integration review, and MLRo on-call support during the embedding period.