Flawless Money Limited | A niche consultancy focusing on payments and dealing with the financial regulation of electronic money, money remittance, and other payments.

Anti-money laundering

Complying with anti-money laundering and counter terrorist financing (AML/CTF) regulation in the EU is one of the most serious challenges faced by a regulated business. Firms are required to establish structures to ensure compliance with AML/CTF regulation in the jurisdiction in which they are based and may also need to establish such structures in other jurisdictions in which they have a presence.

  • Flawless Money’s regulatory and compliance consultants can use their multi-jurisdiction experience to provide the following services:
  • Providing expert advice on the fourth Money Laundering Directive (4MLD) and the fifth Money Laundering Directive (5MLD), as well as supranational and European guidance;
  • Preparing a suite of AML/CTF mandatory documents tailored to individual business requirements, including AML/CTF manuals and accompanying policies and procedures;
  • Providing expert advice and opinions on AML/CTF regulatory obligations across a number of jurisdictions;
  • Carrying out staged regulatory investigations by ex-FCA staff to prepare for FCA visits and reviews;
  • Carrying out regular AML audits to test and evaluate compliance programmes and provide recommendations in the case deficiencies are found;
  • Developing and implementing a risk-based approach to AML/CTF compliance that is tailored to individual products;
  • Advising on the duties and liabilities of the Money Laundering Reporting Officer (MLRO) and the nominated officer;
  • Developing policies and procedures for internal and external suspicious activity reporting;
  • Developing policies and procedures for customer due diligence (CDD), including advising on simplified and enhanced CDD as well as on electronic CDD;
  • Advising on and assisting with the implementation of a transaction monitoring system;
  • Providing general AML/CTF training for staff and specialized AML/CTF training for the MLRO, the board of directors and the nominated officer; and
  • Providing representation when liaising with local FIUs, competent authorities and other law enforcement agencies, both at national and European level.