AML and financial crime

Payment service providers face major regulatory challenges. These include compliance with anti-money laundering (AML), counter-terrorist financing (CTF) regulations and sanctions regimes.

Our team comprises consultants with extensive AML and CTF experience across the UK, EU and ROW. We have been involved in developing industry guidance for the e-money, payments and crypto asset industry. Additionally, we engage with legislators and regulators in consultations and implementations of various legislative frameworks.

Regulatory advisory and representation

We provide expert advice on regulatory obligations. Our team has successfully represented clients with the Financial Conduct Authority, securing favourable outcomes.

We carry out staged regulatory investigations to prepare for FCA visits. Furthermore, we a conduct regular AML audits to evaluate compliance programmes and provide recommendations if we find deficiencies.

Our international clients engage us to develop and implement a risk-based approach to AML/ CTF/ Sanctions compliance that is tailored to individual products. We also advise on the duties and liabilities of designated individuals and the governing board.

Compliance frameworks and risk assessment

We have dedicated experts for drafting policies and procedures addressing key AML obligations such as internal and external suspicious activity reporting and customer due diligence (CDD), including advising on simplified and enhanced CDD, as well as electronic CDD. We can also advise on the implementation of national risk assessments, the UK Joint Money Laundering Steering Group Guidance, as well as EU Supra National Risk Assessments. Our staff can assist in designing risk assessments focusing on product, customer, channel and geographic risks and developing policies that are sensitive to the risks posed.

Training and industry engagement

We provide general AML training for staff and specialised AML training for MLROs, the board of directors and the nominated officer.

Our consultants have participated in FATF hearings, industry groups and regularly assist clients in formulating responses to public consultations on financial crime.

Our financial crime practice extends to issues arising from fraud including regulatory developments relating to authorised push payment scams (APP scams) and the liability of payment service providers for such fraud.