Documentation scope
- AML / CTF policy and procedures
- Business-wide risk assessment
- Customer risk assessment methodology
- CDD and EDD procedures
- PEP and sanctions screening procedures
- Transaction monitoring and suspicious activity escalation procedures
- Record keeping and staff training procedures
Best suited for
- MSB and money-transfer businesses
- Fintech and payment companies
- Digital-asset and crypto businesses
- Businesses preparing for banking or regulatory review
- Existing firms updating outdated or generic documentation
How we work
The drafting process begins with an intake covering the business model, client types, transaction flows, jurisdictions, systems and internal responsibilities. Documentation is then tailored to those facts rather than delivered as an off-the-shelf template.
Review & responsibility
Documentation is prepared based on information supplied by the client and should be reviewed and approved by the company’s management, compliance officer and, where appropriate, local legal or regulatory counsel before implementation or submission.