Fractional Chief AML Officer and MLRO Services

Program ownership and governance

We act as your appointed compliance officer. This means taking accountability for your AML program, interfacing with regulators when required, signing compliance reports, and ensuring your board or management has visibility into compliance status. We establish governance structures, reporting lines, and escalation paths.

Risk assessment and control design

We own your enterprise-wide risk assessment. This includes assessing inherent risks from your products, customers, geographies, and distribution channels, then designing controls that address those risks. We update the risk assessment when you launch new products, enter new markets, or change business models.

CDD and EDD design

We build your customer due diligence framework. This includes risk-based customer segmentation, identity verification requirements, source of funds and wealth procedures, ongoing monitoring triggers, and enhanced due diligence workflows for high-risk customer types. We document what information you collect, when you collect it, and how you verify it.

Transaction monitoring and alert triage support

We design your transaction monitoring approach and support alert review. This includes defining scenarios, setting thresholds, documenting investigation procedures, and determining when to escalate. We review high-risk alerts, provide triage guidance, and document decisions for audit purposes.

Reporting support and audit readiness

We handle suspicious transaction reporting coordination, regulatory correspondence, and audit preparation. When banks, payment partners, or regulators request compliance documentation, we compile evidence packs and respond to inquiries. We maintain audit trails, KRI dashboards, and effectiveness review documentation.