Different Rules. Same Evidence Your Partners Will Ask For
AML requirements vary by jurisdiction, but banks and payment partners apply consistent due diligence standards globally. They want to see qualified compliance ownership, documented policies, risk assessments, and monthly evidence regardless of where you operate. We provide compliance coverage for firms operating across multiple regulatory regimes
Canada
Regulatory framework
FINTRAC supervises reporting entities including MSBs, payment service providers, and certain fintech businesses. Registered entities must maintain compliance programs covering five key elements: appointed compliance officer, written policies and procedures, ongoing training, effectiveness reviews, and risk assessments.
What firms need
Named compliance officer responsible for program implementation, with authority and information access. Complete AML policy framework addressing customer due diligence, transaction monitoring, record keeping, and suspicious transaction reporting. Annual or more frequent risk assessment updates. Training programs with documented delivery and testing. Effectiveness reviews conducted at least every two years.
Banking reality
Canadian banks scrutinize MSB relationships carefully following significant enforcement actions in the sector. They require extensive documentation during onboarding and ongoing evidence of program effectiveness. You must demonstrate that your compliance program meets or exceeds FINTRAC expectations to maintain banking relationships.
How we help
We provide appointed compliance officer services for Canadian reporting entities. We design FINTRAC-aligned AML programs, conduct effectiveness reviews, deliver training, and produce the monthly evidence that banks and auditors request. Our service satisfies the compliance officer requirement while avoiding full time hiring costs.
Offshore Jurisdictions
Regulatory frameworks
Offshore financial centers including British Virgin Islands, Cayman Islands, Bermuda, Bahamas, Gibraltar, and others maintain AML frameworks aligned with international standards. Many jurisdictions require licensed entities to appoint MLROs with regulatory approval or notification in some cases.
What firms need
Named MLRO or compliance officer with documented authority and information access. AML policies and procedures covering the entity’s risk profile and business model. Customer due diligence and enhanced due diligence frameworks. Transaction monitoring appropriate to products and customer types. Ongoing training and effectiveness reviews.
Banking and licensing reality
Offshore entities face heightened scrutiny from banks, payment partners, and even customers. International banks apply strict due diligence to offshore clients regardless of licensing status. You must demonstrate compliance programs that meet international standards, not just local minimums.
Licensing in offshore jurisdictions often includes compliance officer approval or review processes. Regulators assess qualifications, experience, and ability to access information. Some jurisdictions require pre-approval, others accept notification after appointment.
How we help
We provide MLRO and compliance officer services for offshore entities across multiple jurisdictions. We design programs that satisfy local regulatory requirements while meeting the international banking standards that offshore firms must meet to access financial services. We handle regulatory interactions, approval processes where required, and ongoing evidence production.
Europe
Regulatory frameworks
EU member states implement AML directives through national legislation, creating broadly aligned frameworks with local variations. Relevant entities include payment institutions, e-money issuers, crypto asset service providers, and certain other financial businesses. The European Banking Authority provides guidelines on governance and compliance officer roles.
What firms need
Compliance officer or equivalent role with appropriate authority and reporting lines. AML risk assessment covering products, customers, distribution channels, and geographic exposure. Policies and procedures addressing customer due diligence, ongoing monitoring, sanctions screening, and suspicious transaction reporting. Training programs and independent effectiveness reviews.
Market reality
European banks and payment processors apply rigorous due diligence standards. They expect to see qualified compliance ownership, documented controls addressing EU AML frameworks, and evidence of ongoing program operation. Firms operating cross-border within Europe must address multiple national implementations while maintaining unified programs.
EU regulatory expectations have increased following enforcement actions and framework updates. Firms must demonstrate not just policy documentation but actual implementation and effectiveness.
How we help
We provide fractional compliance officer services for EU-based and EU-adjacent firms. We design programs addressing relevant EU directives and member state requirements. We support firms operating across multiple European jurisdictions with unified frameworks that satisfy varied national implementations. Our service includes ongoing evidence production that meets EU banking and payment partner standards.
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Why jurisdiction-specific expertise matters
AML rules differ significantly across jurisdictions. Canada’s FINTRAC framework differs from BVI regulations, which differ from EU directives. The terminology varies, approval processes differ, and specific requirements have local nuances.
However, the underlying compliance program elements remain consistent. All frameworks expect qualified ownership, documented controls, risk-based approaches, training, and effectiveness reviews. The challenge is structuring programs that satisfy specific local rules while meeting universal banking standards.
We design compliance programs that work within your regulatory environment while producing the evidence that all financial partners require. You get local compliance expertise without hiring separately in each jurisdiction.
Multi-jurisdiction operations
Many of our clients operate across multiple regulatory regimes. A crypto platform might hold licenses in Europe, registration in Canada, and entity formation offshore. An iGaming operator might have licenses in Malta and Curacao while serving global customers.
Multi-jurisdiction compliance requires unified programs that address all applicable frameworks. You need:
- One compliance officer covering all entities - Structured appropriately for each jurisdiction's approval or notification requirements
- Unified AML policies - Addressing highest applicable standards while noting jurisdiction-specific variations where necessary
- Consolidated risk assessment - Covering all products, jurisdictions, and customer types across your operations
- Integrated monitoring - Detecting suspicious activity regardless of which entity or jurisdiction a transaction flows through
- Coordinated reporting - Filing STRs or SARs with appropriate regulators while maintaining global view of suspicious activity patterns
We design multi-jurisdiction programs that satisfy local requirements while maintaining operational efficiency through unified frameworks.
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
Yes, in most cases. The compliance officer can serve multiple entities within a corporate group across different jurisdictions. Some regulators require the officer to be approved or notified separately for each license or registration, but the same individual can fulfill the role. We structure appointments to satisfy applicable requirements in each jurisdiction
True conflicts are rare. Usually, jurisdictions have different implementation details but compatible underlying requirements. When standards differ, we apply the higher standard across all jurisdictions. For example, if one jurisdiction requires annual risk assessments and another requires them every two years, we conduct annual assessments. This ensures compliance everywhere while avoiding duplicate work
Not usually. We design unified policy frameworks that address all jurisdictions where you operate, with annexes or sections noting jurisdiction-specific requirements where necessary. One document addressing highest applicable standards is more efficient than maintaining separate policies for each location, and it ensures consistent control application
We monitor regulatory updates, enforcement actions, and guidance publications across the jurisdictions where our clients operate. We track regulator websites, industry associations, and legal updates. When requirements change, we assess impact on client programs and implement necessary updates. Clients don't need to monitor multiple regulators themselves.
Compliance coverage across your operating jurisdictions
Whether you operate in one jurisdiction or many, we provide compliance officer services and policy frameworks that satisfy local requirements while meeting global banking standards
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.
