AFINUR
Advisory›Governance & independent assurance

Your board signs off.
Give it something to stand on.

AML/CFT governance, three lines of defence, the MLRO mandate and independent assurance: AFINUR gives your management and board the evidence the regulator expects.

The three lines of defence

Accountability at
every level of the organisation

We define who decides, who checks and who escalates, across all three lines. No gaps in oversight, no doubt about accountability.

1

Business lines

Own & manage risk

  • Customer acceptance decisions
  • KYC/CDD execution
  • Transaction monitoring alerts
  • First-level escalation
2

Compliance function

Oversee & advise

  • Policy ownership
  • MLRO mandate
  • Regulatory reporting
  • Training & awareness
3

Internal audit

Independently assure

  • Programme effectiveness review
  • Control testing
  • Findings & recommendations
  • Board reporting

Five governance services

From board mandate
to independent assurance.

01

AML/CFT governance & control framework

Design of comprehensive AML/CFT governance frameworks — defining board and senior management responsibilities, compliance committee structures, escalation protocols, and the three-lines-of-defence model. We ensure governance arrangements meet FATF Recommendation 18 and applicable supervisory expectations.

02

Policies & procedures

Development of the full AML/CFT policy and procedure suite — from the overarching AML/CFT policy to granular operational procedures covering KYC, transaction monitoring, sanctions, STR, and record-keeping. All documentation is calibrated to your risk profile and regulatory environment.

03

AML/CFT Operating Model & Compliance Function Design

Design of the AML/CFT operating model — defining the compliance function's mandate, organisational structure, reporting lines, resource requirements, and interaction with business lines. We design MLRO roles, deputy structures, and compliance committee charters aligned to regulatory expectations.

04

Independent audit & compliance testing

We test both the design and the real effectiveness of your controls, as a third line would. You get actionable findings and credible evidence for the regulator.

05

Regulatory Inspection Readiness & Remediation

Pre-inspection diagnostic and remediation support — simulating supervisory examination methodologies, identifying governance and documentation vulnerabilities, and preparing your compliance function, board, and senior management for regulatory scrutiny. Post-inspection remediation planning and implementation support also available.

Is your governance
ready to be audited?

Talk to an AFINUR specialist about your compliance function and your independent assurance needs.

Confidential: all our engagements are covered by professional secrecy.

Independent Governance

Governance is judged on decisions, not organisation charts.

AFINUR designs governance that works every day, not just on audit day. Our independent reviews give the board a clear view of what works, and what must be fixed.

Board meeting on compliance governance
Board-level governance review session with compliance leadership
Governance is not a structure on paper — it is the lived reality of how accountability flows through your institution. We design frameworks that function under pressure, not just under audit.

AFINUR Governance & Assurance Practice

The board at the centre

We give the board and management the committees, reporting lines and escalation rules they need to meet their AML/CFT responsibilities.

A strong MLRO mandate

Authority, resources, independence and direct access to the board: a mandate that meets regulators' expectations.

Independent assurance reviews

Conducted independently of the compliance function, our reviews give the board and audit committee an objective view of programme effectiveness.