Programs that satisfy regulators and withstand examination.

An AML program is judged on its record: the risk assessment behind it, the files that prove client due diligence, and the monitoring that shows someone was watching. We build that record deliberately.
Work is scoped to the obligations that apply to your business, whether that is FINTRAC in Canada or another regulator, and is tested before an examiner tests it for you.
Onboarding that produces a defensible file every time
A program you can evidence, not just describe
Findings resolved before the regulator arrives
Each engagement is scoped to your obligations and reporting requirements. These are the areas we routinely cover.
Policies, procedures, roles and record-keeping built around a documented risk-based approach rather than a template.
Client identification and verification standards, beneficial ownership, PEP and high-risk file requirements, plus file reviews against them.
Alert thresholds and escalation paths, large cash and electronic funds transfer reporting, and suspicious transaction escalation.
Effectiveness testing of the whole program with findings rated, evidenced and tracked through to remediation.
Client and product risk-rating models with documented criteria, so onboarding decisions are consistent and defensible.
Role-specific training, attendance records and a compliance report that gives leadership the information it needs.
We document the money laundering and terrorist financing risks of your clients, products, channels and geography.
Policies, procedures and controls are built from that risk assessment, with clear ownership and record-keeping requirements.
Onboarding, monitoring and reporting workflows are put in place and tested on live files.
The program is reviewed against its own requirements, findings are rated, and remediation is tracked to closure.
In Canada, reporting entities include financial entities, money services businesses, dealers in precious metals and stones, real estate brokers, and several other sectors. We confirm your obligations as part of the risk assessment.
Yes. File reviews are run on a sample basis to an agreed schedule, with findings reported in one register rather than as ad hoc emails.
We provide role-specific training for frontline staff, compliance officers and boards, with attendance and content records you can produce on request.
We will confirm scope, timing and what we need from your team before any work begins.
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