A structured five phase methodology
Each engagement is partner-led from scoping to final report, and each phase concludes with defined deliverables.
Mobilize
Scope, data requests, stakeholders and a fixed plan. Started within two weeks of instruction.
A signed scope and data planDiagnose
Evidence drawn from the institution's data, documentation and people, directed at root causes.
Findings tested against institutional dataDesign
Rules, procedures, frameworks and operating models, drafted and ready to adopt.
Drafted rules and proceduresDeliver
Implementation support alongside internal teams until changes are embedded.
Controls running in productionReport
A clear account for management, the board and, where needed, the regulator.
A report with evidence attached
Four measures of a successful engagement
Does the program meet regulatory requirements and withstand supervisory review?
Findings closed and accepted by the regulator, gaps against requirements resolved, no repeat findings at the next inspection or audit.
Do the controls detect and prevent the risks that matter most?
Coverage of the institution's key risks, quality of suspicious transaction reports, true positive rates and fraud losses prevented.
Is the cost of the function proportionate to the risk it manages?
Alert volumes, false positive rates, time to disposition, backlogs and manual effort per case.
Will the improvements hold after the engagement ends?
Controls owned and operated by internal teams, procedures documented, staff trained and results evidenced for audit and the board.
Four commitments on every engagement
Partner led delivery
The partners who scope the work lead the fieldwork and write the report.
Implemented solutions
Findings are accompanied by calibrated rules, documented procedures and frameworks that operate in practice.
Independence
No vendor ties, and every referral disclosed. We do not validate remediation we designed for the same client. Conflict and sanctions screening precedes every proposal.
Prompt mobilization
Engagements are scoped within one week and mobilized within two. Defined scopes are offered on a fixed fee basis.
Trusted advisors with direct industry experience
Our partners have held senior positions in industry, law enforcement and government, supported by a team of industry experts. We understand the commercial realities of financial institutions and the businesses that depend on them, the expectations of supervisors and the accountability of boards and senior management.
Commercial understanding
We approach compliance with an understanding of the business it serves. Controls must be both effective and efficient, and we design them to meet both objectives.
Technical capability
Our partners build as well as advise. The team includes SAS Certified Advanced Programming for SAS 9.4 capabilities, with extensive experience developing analytical systems and databases for the analysis of financial intelligence, alongside direct work on transaction monitoring, screening, fraud detection and AI models.
Independent advice
We provide boards, Chief Executive Officers, Chief Risk Officers, Chief Compliance Officers and MLROs with independent, evidence based advice on risk appetite, regulatory exposure and the decisions that follow.
Implemented solutions
Our work concludes with controls, procedures and frameworks that are implemented, operating and able to withstand supervisory and audit scrutiny.
Balancing cost, loss and customer outcomes with regulatory expectations
The FATF risk based approach requires institutions to understand their financial crime risks and apply controls proportionate to them, with enhanced measures where risk is higher and simplified measures where it is lower. Applied well, it directs resources to the most material exposures and avoids unnecessary friction for legitimate customers. We help institutions calibrate that approach and evidence it to the board and to supervisors.
- Cost
- Controls proportionate to the risk, with fewer false positives and less manual review.
- Loss
- Detection and prevention focused on the exposures most material to the institution.
- Customer experience
- Onboarding, screening and monitoring without undue friction for legitimate customers.