Marco PaceAML · FINANCIAL CRIME · ADVISORY
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AML Check

AREAS OF SUPPORT

Rules and operations.
Decisions that can be explained.

AML procedures, gap reviews, corrective plans, controls testing, customer due diligence and training. For professional firms, businesses and financial operators, with scope defined around the actual need.

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

Describe your need Compare the support options
A banking issue has already arisen? Explore restricted accounts, held payments and requests for information.

Not sure where to start? AML Check helps frame the need. Already have an AML framework? The readiness Radar helps identify an area to examine. Both are optional self-orientation tools, not consultancy assessments.

01 · POLICIES, PROCEDURES AND GAP ANALYSIS

Usable procedures and clear change priorities

For professional firms and organisations subject to AML duties.

Draft, review and update AML/CFT policies and procedures, translating requirements and actual practice into roles, checks, escalation and record-keeping instructions. Gap analysis identifies weaknesses and separates current duties from future AMLR preparation.

  • Scope, AMLR gap analysis and roadmap
  • BWRA and customer risk assessment
  • CDD, EDD and beneficial ownership
  • Policy, governance and training
THE OUTPUT

Agreed policies and procedures, a change log and an implementation plan; for gap analysis, a requirements-to-gap matrix and a roadmap with priorities, owners and expected evidence.

Define the readiness scope
02 · CDD/EDD AND FINANCIAL CRIME ADVISORY

Strengthen decisions and controls

For professional firms and AML teams in payment firms, EMIs and other financial operators reviewing complex customers or transactions.

Specialist review of customer files, beneficial ownership, source of funds and wealth, alerts and transactions: connect the information, identify gaps and structure further checks and escalation.

  • Transaction monitoring and escalation
  • High-risk CDD and EDD
  • Source of Funds and Source of Wealth
  • Remediation and second-line review
THE OUTPUT

A file or process summary, missing information and the rationale for proposed checks and escalations. Decisions remain with accountable functions; specialist support has an agreed scope.

Discuss the process to review
03 · AML CONTROLS TESTING

Test whether the control actually works

For AML/Compliance functions and organisations that need to test processes, files or corrective actions.

A control is not effective simply because it is well documented. Testing examines whether the control is fit for purpose (design effectiveness) and performed effectively in practice (operating effectiveness), selects evidence in line with risk and separates isolated errors from systemic weaknesses.

  • Design and operating effectiveness
  • File review and risk-based sampling
  • CDD/EDD, escalation and transaction monitoring
  • Root cause, remediation and closure testing
THE OUTPUT

Evidence-linked findings, cause and impact, with prioritised actions and clear criteria for validating closure.

Before testing, agree the objective, population and sample, criteria, access to evidence and limitations. Define the nature of the engagement and any independence requirement separately from remediation support.

Define the testing scope

AUDIT FINDINGS REMEDIATION · INSPECTIONS

Turn a finding into a verifiable corrective plan.

For firms and organisations with audit, compliance or supervisory findings: analyse the finding and root cause, define corrective actions, owners and deadlines, and follow up on progress and closure evidence. Professional interaction with authorities and supervisors helps me understand the expectation behind the request, without replacing the obliged entity’s responsibilities or promising the outcome of a review.

OUTPUT TO AGREE

A corrective plan and follow-up register linking finding, cause, action, owner, due date, status and closure evidence. Formal closure remains with the competent function or authority.

Discuss a finding or inspection →

AUTHORISATION · LICENSING · REGULATORY CHANGE

A licence is more than an application: controls need to be credible before authorisation.

For regulated firms and authorisation projects, I can support the AML/CFT workstream: business risk assessment, CDD/EDD, governance, escalation, transaction monitoring, policies, evidence and key-function readiness. Support can also cover changes of control, acquisitions or material changes where the AML framework needs to remain coherent with the new operating model.

SCOPE OF SUPPORT

Preparation and challenge of the AML/CFT framework and the evidence supporting it, coordinated with legal advisers, corporate service providers and other authorisation specialists. This does not replace legal advice or regulatory representation and does not guarantee that an authorisation will be granted.

Example output to agree: AML/CFT requirement → available evidence → gap → owner → priority. The business model, jurisdictions and type of authorisation determine the review scope.

Define the AML authorisation workstream →

TAILORED AML TRAINING

Training built around the organisation’s actual risk.

Sessions and workshops for professional firms, businesses and internal teams, shaped around their activity, customers, transactions and real risk exposure. The aim is not to repeat regulation, but to translate it into red flags, decisions, controls and cases that can be applied in day-to-day work.

TRAINING EVIDENCE

The agreed scope may include the programme, duration, attendees, cases or exercises, an optional learning check, a training record and an individual attendance/completion certificate.

How we build the training programme →

WORKING MODEL

Clear scope, usable output.

  1. 01UnderstandContext, perimeter, risk and objective.
  2. 02AssessGaps, evidence and real priorities.
  3. 03TranslateActions, responsibilities and verifiable outcomes.
Discuss the scope of support