Five core controls
Five controls.
No blind spots.
01
Customer due diligence & KYC
Client identification and verification, beneficial ownership, enhanced due diligence, PEPs and ongoing monitoring: we build risk-based KYC in line with FATF Recommendations 10, 12 and 22 and your national rules.
Deliverables
- KYC/CDD policy and procedures
- Customer risk rating methodology
- Beneficial ownership framework
- EDD for high-risk clients
02
Sanctions screening
Screening policy, list management (OFAC, EU, UN, OFSI), matching rules, alert handling and escalation: we design your programme, then tune it to cut false positives without missing true matches.
Deliverables
- Sanctions policy
- Screening calibration review
- Alert handling procedure
- Escalation and false-positive clearance procedures
03
Transaction monitoring
Scenario selection, thresholds, alert triage, case management and model validation: fewer useless alerts, and genuine suspicion escalated in time.
Deliverables
- Scenario library and calibration
- Alert triage procedures
- Case management framework
- Model validation report
04
Suspicious transaction reporting
Suspicion criteria, internal escalation, FIU reporting format and staff training: your reports are filed on time and well documented, and the institution is protected against tipping-off risk.
Deliverables
- STR policy and procedures
- Suspicion indicators
- FIU reporting templates
- Staff training programme
05
Correspondent banking due diligence
Correspondent assessment, Wolfsberg questionnaires, ongoing monitoring and de-risking decisions: a programme aligned with FATF Recommendation 13 and the Wolfsberg Principles.
Deliverables
- Correspondent banking policy and procedures
- Correspondent assessment framework
- Wolfsberg questionnaire templates
- De-risking decision framework
Our approach
One joined-up programme,
from risk to evidence.
Your controls work as one system, not a stack of separate policies. Each one flows from your risk assessment and is documented for inspection.
THE COMPLIANCE CYCLE
Risk assessment
Every control starts from your risk profile
Policies
Policies that meet your rules
Controls
Applied in every business line
Testing
Effectiveness independently verified
Ongoing monitoring
Settings reviewed continuously
Ready to show
your controls to the regulator?
Talk to an AFINUR specialist about your AML/CFT programme and which controls to strengthen first.
Confidential: all our engagements are covered by professional secrecy.
From policy to day-to-day control
We build the AML/CFT programme from policies down to daily controls, consistent at every level.
Inspection-ready
Every deliverable is built to be shown to the regulator, FATF assessors and internal audit.
Every sanctions regime
EU, OFAC, UN and UK, including multi-jurisdiction exposure and correspondent banking risk.
Suspicious reporting
A reporting process that meets the legal duty without overloading your teams.
Further reading