Do you work alongside an existing compliance team?

Almost always. We are engaged to add independence, capacity and specialist detection expertise — not to displace the function that will own the program after we leave.

Can findings be used in a regulatory response?

Yes. Deliverables are written to be produced to a regulator, with methodology, sampling basis and limitations stated explicitly.

Brief / CIG-SVC-01

AML program design, assessment and financial crime prevention

Modern money laundering does not look like a textbook typology. We help institutions calibrate programs against real, current threat patterns — layered trade-based schemes, mule networks, virtual asset off-ramps, and correspondent banking pass-through.

An AML program is only as good as its worst-calibrated control. We rebuild the chain end to end — risk assessment, segmentation, detection logic, alert triage, investigation quality and disclosure narrative — so that each layer is evidenced, tested and explainable to an examiner.

§ 01Method

DOMAIN / AML

REVIEW / HUMAN-ADJUDICATED

01
Threat-led risk assessment
We start from the typologies that actually touch your book: trade-based layering, third-party payment processors, mule and money-transfer networks, virtual asset off-ramps, nested correspondent relationships and professional enabler structures. Inherent risk is scored against products, channels, customers and geographies, then tested against real transaction history rather than assumption.
02
Detection engineering and model validation
Scenario logic is decomposed, thresholds are re-derived from population statistics, and above/below-the-line testing quantifies what each rule catches and what it misses. We document tuning rationale to the standard a model risk function or examiner will demand, including data lineage, segmentation logic and false-positive economics.
03
Investigation and disclosure quality
We sample closed alerts and filed disclosures, grade them against an evidentiary rubric, and rebuild the narrative standard. A SAR that states what is known, what is inferred and what remains unverified is materially more useful to a financial intelligence unit than a template.
04
Remediation and lookback execution
Where historic coverage failed, we scope and run the lookback: population definition, sampling defensibility, investigator training, quality assurance and reporting cadence — with the audit trail assembled as the work proceeds, not reconstructed afterwards.

// Scope of work

01AML program assessments aligned to FATF, EU AMLD, FinCEN, MAS and FCA
02Financial crime risk frameworks and residual risk methodology
03Transaction monitoring tuning, scenario design and model validation
04SAR/STR quality reviews and disclosure narrative uplift
05Investigative reviews of suspected money laundering activity
06Regulatory readiness for examinations, s.166 reviews and consent orders

// Deliverables

D01Enterprise-wide financial crime risk assessment with residual risk methodology
D02Transaction monitoring tuning report with above/below-the-line evidence
D03Model validation pack suitable for model risk governance review
D04SAR/STR quality rubric, sampled grading and narrative standard
D05Regulatory readiness assessment and examination response playbook
D06Remediation and lookback plan with QA framework

§ 02When to engage

// Trigger

Alert volumes rising without a corresponding rise in quality disclosures

// Trigger

Thresholds inherited from a vendor default and never re-derived

// Trigger

Examination findings on program governance or monitoring coverage

// Trigger

New product, channel or jurisdiction launched ahead of the control set

// Trigger

Correspondent or sponsor bank pressing for evidence of program maturity

// Outcome

"Programs that a regulator can defend and an operator can actually run."

§ 03Questions

Do you work alongside an existing compliance team?: Almost always. We are engaged to add independence, capacity and specialist detection expertise — not to displace the function that will own the program after we leave.
Can findings be used in a regulatory response?: Yes. Deliverables are written to be produced to a regulator, with methodology, sampling basis and limitations stated explicitly.