FOR ACCOUNTANTS · LAWYERS · NOTARIES

The firm remains the trusted adviser.
AML complexity becomes manageable.

Specialist support for non-routine engagements and clients, without replacing the professional relationship or legal and tax advice.

Support also extends to Corporate Service Providers (CSPs), trustees and fiduciary service providers, for their own AML needs and complex client matters.

Describe the firm’s case How I can support the firm

WHEN TO INVOLVE AN AML SPECIALIST

Scope or obligations are unclear

The client’s actual activity does not allow an immediate conclusion on perimeter, obligations or the depth of review required.

Ownership or structure is complex

Corporate chains, multiple jurisdictions or beneficial-ownership information need to be read together rather than in isolation.

Funds, risk or transaction are non-routine

PEPs, sensitive geographies, source of funds/wealth, high values or economic rationale call for proportionate, reasoned checks.

A second AML reading is useful

The firm retains the client and professional decision; specialist input helps structure the analysis, evidence and possible next checks.

A finding or inspection arrives

An authority request, finding or inspection phase may require rapid reconstruction of facts, controls, responsibilities and evidence, followed by a clear and verifiable response.

A PRACTICAL RULE

Formal completeness and understanding the risk are not the same thing.

Engagement→Client & UBO→Funds & geographies→Coherence→Decision

The value of a second reading lies in the connections: a file can contain the expected documents and still leave the most important question open — does the overall story make sense?

HAS THIS HAPPENED TO YOU?

Risk often enters the firm disguised as an ordinary request.

These are not automatic conclusions. They are moments when a routine file may deserve a second AML reading.

A long-standing client changes structure

A familiar company introduces a foreign holding, new shareholders or a vehicle that makes ownership less immediate.

SignalComplexity increases without an immediately clear economic rationale.

QuestionWho ultimately controls the structure, and why has it changed now?

The property is simple. The funds are not

A transaction looks straightforward, but buyer, funder, source account and price do not reconcile easily.

SignalThird-party funding, multiple jurisdictions or source of funds inconsistent with the known profile.

QuestionDoes the information explain the whole transaction, or only the client?

The documents exist, the story does not

Corporate records and declarations are available, yet together they do not explain purpose, flows or counterparties.

SignalFormal completeness without substantive coherence.

QuestionIf challenged today, which evidence would support the decision?

The wealth is significant, but its story still needs to be reconstructed

A PEP or high-net-worth client needs to document an investment, a business sale or funds held across companies, property and multiple jurisdictions.

SignalA bank statement shows where funds are held, but not by itself how the wealth was generated or how it reached the transaction.

QuestionDo SoW, SoF, structure and evidence tell the same story?

Frame the case with AML Check

Scenarios draw on recurring risks in FATF guidance for the accounting profession; each real case requires individual assessment.

A REAL CASE, A PRACTICAL QUESTION

Ongoing investigation; no conviction announced

An invoice does not explain the payment by itself

The documented case

In their 6 October 2026 release, the Mons prosecutor and Belgian Federal Police describe suspected compensation laundering involving shell companies, straw directors, false invoices and flows without economic justification. The 29 September action included 15 searches and two people placed under arrest warrant.

What to check

Reconcile the invoice, actual service, supplier’s capacity and payment recipient. If they align only on paper, which independent evidence explains who works, who controls and why the money follows that route?

Procura di Mons / Belgian Federal Police · 06.10.2026 ↗

Connect structure, service and financial flows →

Investigation and preventive seizure; presumption of innocence

Financial solidity must exist beyond the accounts

The documented case

In Nuovi Orizzonti, EPPO reports a €1.98 million preventive seizure. Investigators allege that tax advisers and accounting service centres established strawman companies and falsified accounts to display non-existent financial solidity and obtain public funding. These are allegations, not final findings of responsibility.

What to check

What supports reported assets, liquidity and works? Compare accounting data, bank confirmations and directors’ autonomy. A request to fix the figures requires clarity about underlying evidence and the engagement’s scope before proceeding.

EPPO · marzo / March 2026 ↗

Explore a specialist second review →

Cases reflect the status reported in the cited release. Practical questions are professional applications: no indicator alone establishes wrongdoing or automatically determines reporting, refusal or approval of a transaction.

WORKING METHOD

From uncertainty to a documentable decision.

A defined engagement built around information that is actually available.

01FrameActivity, client, transaction and applicable rules.
02ConnectBeneficial ownership, funds, geographies and economic purpose.
03IdentifyGaps, missing information and proportionate checks.
04DeliverA usable analysis and a trace of the decisions taken.

WHAT THE FIRM RECEIVES

Support that integrates, without taking over.

Clear scope

Objective, responsibilities and output agreed before work begins.

Reasoned priorities

Not an undifferentiated list: what to investigate, why and with what urgency.

Relationship preserved

The firm remains the client’s adviser while integrating specialist AML capability.

More structured supervisory dialogue

Support in reading requests and findings and preparing evidence, remediation and communications, without replacing the firm or obliged entity.

Describe the case to review

The firm remains the trusted adviser.AML complexity becomes manageable.