AML Policies and Procedures That Pass Audits
We design complete AML frameworks tailored to your actual operations. Not templates. You get editable policies, procedures, risk assessments, training plans, and monitoring approaches that satisfy banks, auditors, and regulators.
What's included in the policy package
Policies and procedures
Core AML policy document covering your program scope, risk-based approach, governance, and compliance with applicable frameworks. Detailed procedures for customer onboarding, identity verification, source of funds collection, ongoing monitoring, sanctions screening, PEP identification, alert investigation, suspicious transaction reporting, recordkeeping, and training.
Roles and responsibilities
Clear documentation of who does what. Compliance officer role definition, business unit responsibilities, escalation paths, approval authorities, and management oversight requirements. This includes defining interactions with other functions like legal, finance, operations, and customer service.
Training plan
Structured training program covering initial training for new hires, ongoing training schedules, role-specific training requirements, testing and assessment approach, and recordkeeping. We provide baseline training materials you can customize and deliver.
Monitoring approach
Transaction monitoring methodology document explaining your scenarios, thresholds, tuning approach, alert triage process, investigation standards, and documentation requirements. This is what auditors ask to see when they want to understand how you actually detect suspicious activity.
Recordkeeping requirements
Documentation standards covering what records you keep, how long you retain them, where they’re stored, and who can access them. This includes CDD records, transaction data, alert investigations, STR filings, training records, and audit trails.
STR workflow
Suspicious transaction reporting procedures including recognition of red flags, investigation requirements, decision criteria for filing, approval process, filing timelines, and post-filing protocols. We map this to your internal systems and escalation paths.
Governance and oversight
Board or management reporting templates, compliance committee structures if applicable, effectiveness review methodology, independent testing approach, and control update procedures. This is how you demonstrate ongoing program oversight.
What we need from you
We can’t write effective policies without understanding your business. During the scoping phase, we gather:
01
Product and service details
What you offer, how customers use your platform, pricing structures, transaction types
02
Customer information
Who your customers are, geographic distribution, typical transaction patterns, high-risk customer segments
03
Jurisdictions and licensing
Where you're licensed or registered, what regulatory frameworks apply, any specific regulator requirements
04
Payment and transaction flows
How money moves through your platform, payment methods accepted, withdrawal processes, third-party integrations
05
Technology and data
What systems you use for onboarding, monitoring, screening, and recordkeeping, what data you capture and where it lives
06
Current controls
What you're already doing for identity verification, screening, monitoring, and reporting, any existing documentation
The more complete this information, the faster we can deliver tailored policies that match your actual operations
What you get at delivery
Editable documents
Microsoft Word files for all policies and procedures. You own the documents and can modify them as your business changes. No ongoing license fees, no proprietary formats. We deliver clean, professional documentation you can share with auditors, banks, and regulators.
Supporting evidence pack
Templates and frameworks that support policy implementation. This includes risk assessment template with your risk factors pre-populated, training presentation slides, compliance calendar showing ongoing tasks, KRI dashboard template, and audit checklist mapping policies to evidence requirements.
Implementation guidance
Brief notes explaining how to put the policies into practice, what systems or tools you’ll need, and what records to maintain. We flag any gaps between your current state and the documented procedures so you know what to fix.
Review and revision cycle
We incorporate your feedback during the design phase. You review draft policies, flag anything that doesn’t match your operations, and we revise accordingly. Delivery includes one final revision after you’ve tested the procedures internally.
Common policy gaps we fix
Generic templates that don’t match operations
Many firms start with downloaded templates or consultant deliverables that use placeholder language like “the firm shall implement risk-based procedures.” These don’t survive audits. We write specific procedures tied to your actual products, systems, and customer types.
No connection between risk assessment and controls
Policies often list controls without explaining what risks they address. Auditors want to see the linkage. We map each control to specific risks in your risk assessment so the logic is clear.
Unclear ownership and escalation
Procedures fail when no one knows who’s responsible. We define clear ownership for each procedure, specify approval authorities, and document escalation paths for edge cases and exceptions.
Missing evidence and recordkeeping standards
Banks and auditors ask what records you keep and for how long. Many policies skip this entirely. We document what you need to retain, where it should be stored, and what audit trail you must maintain.
Monitoring approach without implementation details
Saying “we monitor transactions for suspicious activity” doesn’t satisfy anyone. We document your specific scenarios, thresholds, alert triage process, investigation standards, and decision criteria for escalation.
Training without structure
Firms often deliver ad hoc training without tracking who was trained, what was covered, or whether staff understood the material. We build structured training programs with testing, recordkeeping, and refresh requirements.
Our general frequently asked question service
Our FAQ section provides quick answers to the most common questions so you can find the information you need instantly
Templates give you generic language you have to customize yourself. We write policies from scratch based on your actual business. We reference your specific products, customer types, jurisdictions, systems, and controls. The result is documentation that accurately describes what you do and why you do it, not placeholder text that forces you to figure out implementation.
Yes. Many clients have outdated policies that need refresh. We review your current documentation, identify gaps and inconsistencies, update language to reflect current operations and regulatory expectations, and deliver revised versions. This is usually faster and less expensive than starting from scratch.
It depends. If the new product has different risk characteristics, customer types, or transaction flows, your policies should address those differences. We can perform a gap analysis and update relevant sections rather than rewriting everything. Minor product changes often don't require policy updates if your existing risk-based framework already covers the activity
Our policies address common AML framework expectations that apply across most jurisdictions. We tailor content to the regulatory frameworks that govern your business, whether that's FINTRAC in Canada, EU AML directives, offshore financial center rules, or other regimes. We can't guarantee regulator approval of any document, but we design policies that align with published regulatory guidance and industry standards. This is not legal advice, and we recommend review by local counsel if you have specific licensing or approval concerns.
Audit-ready policies in two weeks
If you need documentation to satisfy bank onboarding, pass an audit, or meet licensing requirements, we can deliver complete policy packages quickly.
Professional AML Consultants for Forex, iGaming, Crypto, and Payment Firms
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We provide named AML compliance officers and audit-ready policies for high-risk fintechs. Fixed monthly plans. Fast start. Built for firms that need to show evidence to banks, regulators, and auditors.