Financial crime controls
AML / CFT work that can be walked, not only signed.
Money-laundering and terrorist-financing duties fail in the gap between a board-approved manual and the onboarding desk. This mandate rebuilds that gap as named steps, risk factors and evidence.
Mandate A
AML / CFT
What this mandate is for
Use it when you take on customers, move value, or must answer a bank, shareholder or supervisor about how you know who you deal with. Typical triggers: a correspondent questionnaire, a new product, staff turnover in the control function, or a finding that policies were copied and never operated.
Working sequence
We start with the activity you actually run — not a template for a different licence. Then: source mapping to applicable AML/CFT rules and licence conditions; interviews on onboarding, screening, payment release and escalation; a risk assessment that uses your customer types and geographies; CDD/EDD logic with clear upgrade triggers; a monitoring narrative that matches your systems rather than inventing alerts you cannot generate; a training outline for the roles that touch the risk; a management pack that states residual risk in plain language.
Deliverables
Business-wide risk assessment, procedure set, control and owner register, sample file checklists, issues log, short board note. You keep operational responsibility for filings and day-to-day decisions.
Intended customer
Intermediaries, payment businesses, trading firms with high-risk counterparties, and licensed operators whose bank file has gone stale. If you need courtroom defence or a nominated officer appointment, say so on the briefing form; that is a different contract. Related reading: sectors, offer, engagement.