AML / CTF
AML/KYC programme design
Risk-based policies, procedures and controls built around your real customer base and transaction flows | not adapted from a generic template.
What it is
What does an AML/KYC programme build actually involve?
An effective AML/KYC programme starts with an honest risk assessment of your specific business | customer types, geographies, products and transaction typologies | and builds controls proportionate to that risk. We design the policy, the customer due diligence workflow, the country risk methodology, and the monitoring logic together, so they hold up as one coherent system rather than a stack of disconnected documents.
Where a programme already exists, we start with a structured gap analysis: contradictions between stated policy and actual procedure, outdated regulatory references, and country-list errors are flagged explicitly rather than smoothed over.
Packages
Choose the level of coverage you need
Assessment
Gap Analysis
A structured review of your existing AML/KYC programme against current regulatory expectations.
Get started- ✓Policy & procedure review
- ✓Colour-coded findings log by severity
- ✓Country risk list validation
- ✓Policy rebuild
- ✓Monitoring rule design
- ✓Vendor selection support
Build
Full Programme
Complete AML/CTF policy, procedures and monitoring logic, built or rebuilt around your risk profile.
Get started- ✓Business-wide risk assessment
- ✓AML/CTF policy & procedures
- ✓CDD/EDD workflow design
- ✓Country & counterparty risk methodology
- ✓Transaction monitoring rule design
- ✓Ongoing quarterly review
Build + Maintain
Managed Programme
Full programme build, plus quarterly reviews to keep it current as your business evolves.
Get started- ✓Everything in Full Programme
- ✓Quarterly policy & risk review
- ✓Vendor selection support
- ✓Regulatory change monitoring
In detail
What's inside the service
Business-wide risk assessment
A documented assessment of customer, geographic, product and channel risk specific to your business.
Policy & procedures
AML/CTF policy and operating procedures that match what your team actually does day to day.
Country & counterparty risk methodology
A defensible, regularly validated risk tiering | checked carefully against EU/EEA membership to avoid erroneous prohibitions.
CDD / EDD workflows
Customer due diligence and enhanced due diligence procedures, including PEP handling that doesn't contradict itself.
Transaction monitoring design
Rule logic and thresholds calibrated to your actual typologies, not a generic rule library.
Reporting & escalation pathways
Clear internal escalation and suspicious activity reporting procedures with named accountability.
FAQ
Frequently asked questions
What's included in an AML/KYC programme build?+
A business-wide risk assessment, AML/CTF policy and procedures, customer due diligence and enhanced due diligence workflows, a country and counterparty risk methodology, and transaction monitoring rule design.
Can you work from an existing policy instead of starting from scratch?+
Yes. Most engagements start with a gap analysis of the existing policy, flagging contradictions, outdated references and jurisdictional errors before rebuilding the affected sections.
Do you help select transaction monitoring or KYC vendors?+
Yes, on the Managed Programme package. We assess vendors against your risk profile and integration needs and support the selection and configuration process.