A tailored AML framework is not a policy with the applicant’s name inserted. It begins with product, customers, geography, assets, custody, cash exposure, providers and transaction behaviour, then configures controls around those risks.
Risk assessment drives acceptance
Define prohibited, restricted and enhanced-review customers, countries, assets, channels and counterparties. Make the score and approval authority understandable to staff and management.
Connect identity and transaction evidence
KYC/KYB, beneficial ownership, PEP/sanctions, source checks and KYT should feed one case and escalation process. Conflicting information or unexplained wallet behaviour must not remain in separate systems without resolution.
Design alerts for the real model
Rules and thresholds should reflect expected customers, volumes, corridors, assets, velocity, cash and counterparty risks. Record disposition, rationale, escalation and reporting decisions.
Test quality and management oversight
Sample files and alerts, measure backlog and ageing, review overrides, track training competence and provide management with useful risk and performance information.