Financial Crime & AML Consultants

Which control area needs review?

Choose the point where the current framework needs clearer evidence or ownership.

• Risk assessment

  Refresh business-wide and customer-risk analysis.

• CDD and KYC

  Review onboarding, verification and ongoing due diligence.

• Monitoring and SARs

  Test transaction monitoring and escalation routes.

• Sanctions and fraud

  Strengthen screening, alert handling and controls.

Who does the work

The team on a financial-crime engagement, and what each part of it brings.

How MEMA helps

A financial-crime framework is judged on whether it works, not on whether it exists. The engagement is built to produce evidence of both.

1. 1Assess the riskA business-wide risk assessment grounded in your customers, products, delivery channels and geographies — the document everything else has to be consistent with.
2. 2Design proportionate controlsCustomer due diligence, sanctions and monitoring arrangements calibrated to that risk assessment, so the controls are defensible as a set rather than individually.
3. 3Embed it with the people who use itProcedures written for the staff who apply them, with training and escalation routes that match the actual decision points in the business.
4. 4Test whether it worksSample testing and control assurance against the framework, so weaknesses surface in your own review rather than in a supervisor's.
5. 5Report and improveMLRO reporting, issue tracking and a documented cycle of change, which is what demonstrates the framework is maintained and not just adopted.

What an AML Review Covers

When a regulated firm engages MEMA as AML compliance consultants, we assess each part of an effective financial crime programme, from the regulatory foundation through to governance and ongoing monitoring. Here is what that review covers in practice.

1. 1Business-Wide Risk AssessmentRegulation 18 of the Money Laundering Regulations 2017 (MLR 2017) requires every regulated firm to produce a documented business-wide risk assessment (BWRA) covering customer types, geographies, products and delivery channels. Our AML consultants review whether your BWRA is genuinely risk-based, kept up to date, approved at senior management level, and capable of withstanding FCA scrutiny. For firms without a BWRA, we draft one from scratch, calibrated to your specific business model rather than a generic template.
2. 2Customer Due Diligence (CDD) and KYC ControlsCustomer due diligence is the operational core of AML compliance. Our financial crime consultants assess whether your CDD procedures are proportionate to the risks in your customer base: standard CDD for lower-risk customers, enhanced due diligence (EDD) for higher-risk relationships including politically exposed persons (PEPs), high-risk jurisdictions, and complex ownership structures. We also review ongoing monitoring arrangements and customer risk rating systems to confirm they reflect actual exposure.
3. 3Transaction Monitoring and SAR ProceduresTransaction monitoring generates alerts; the test is whether your firm can investigate them effectively and file Suspicious Activity Reports (SARs) to the National Crime Agency when warranted. Our AML compliance consulting covers rule calibration to reduce false positives, alert investigation procedures, SAR drafting guidance, and tipping-off controls. We also review your MLRO's SAR decision log to confirm the nominated officer is exercising genuine judgment rather than rubber-stamping outcomes.
4. 4AML Policies, Screening Reviews and MLRO ReportingRegulation 19 of MLR 2017 requires written policies, controls and procedures proportionate to the firm's risks, so we write or rewrite them for the people who apply them. We also review sanctions and PEP screening, including list coverage, match handling and whether alert decisions record their rationale, whichever system you use, and support the MLRO with board reporting.
5. 5Staff Training, Independent Audit and GovernanceRegulation 24 of MLR 2017 requires regular AML training for all relevant employees, tailored to the firm's specific risk profile, not a generic e-learning module. Our consultants design training programmes, review records of delivery, and assess whether staff can identify red flags relevant to your business. We also scope and conduct independent audits of AML systems and controls, a requirement the FCA increasingly tests during supervisory visits and skilled person reviews.

AML Compliance Services and Financial Crime Controls

Seven primary areas of financial crime consulting to protect your organisation

• Anti-Money Laundering (AML)

  Comprehensive AML compliance frameworks

  • AML risk assessments
  • Policy and procedure development
  • Regulatory compliance monitoring
  • AML training programmes

• Risk & Regulation

  Strategic risk assessment and regulatory alignment

  • Financial crime risk mapping
  • Regulatory change impact analysis
  • Control framework design
  • Board-level reporting

• Know Your Customer (KYC)

  Customer due diligence processes

  • CDD and EDD procedures
  • Ongoing monitoring frameworks
  • PEP and sanctions screening
  • Customer risk rating systems

• Transaction Monitoring

  Surveillance of suspicious financial activity

  • Transaction monitoring rules
  • Alert investigation procedures
  • SAR filing support
  • System optimization

• Fraud Prevention

  Detection and prevention mechanisms

  • Fraud risk assessments
  • Prevention controls design
  • Detection system implementation
  • Incident response procedures

• Anti-Bribery & Corruption

  FCPA and UK Bribery Act compliance

  • ABC policy development
  • Third-party due diligence
  • Gifts and hospitality procedures
  • Whistleblowing frameworks

• Sanctions Compliance

  Sanctions screening and compliance programmes

  • Sanctions screening systems
  • Embargo compliance
  • Licence application support
  • Sanctions risk assessments

What you will need to produce

• Business-wide risk assessment
• CDD, KYC and sanctions procedures
• Monitoring and SARs framework
• MLRO reporting and control testing

Outsourced MLRO Services

Firms within scope of the Money Laundering Regulations must appoint a nominated officer to receive internal reports and decide on SARs, and FCA-authorised firms covered by SYSC 6.3 must also appoint an MLRO (SYSC 6.3.9R). In core and enhanced SM&CR firms the MLRO is the SMF17 function, which needs FCA approval. For many smaller or newly authorised firms an outsourced MLRO is the most practical way to meet that obligation with genuine expertise. Where the role is not an SM&CR senior management function (for example in limited scope firms, payment and e-money institutions, and MLR-registered firms), a named MEMA consultant can act as your outsourced MLRO; in core and enhanced SM&CR firms the MLRO is the SMF17, a senior management function that needs individual FCA approval, and MEMA's consultants do not take that function on: we work alongside your approved SMF17 instead.

1. 1What an outsourced MLRO doesWhere a MEMA consultant acts as your outsourced MLRO (outside the SMF17 function), they receive internal suspicious activity reports, exercise independent judgment on whether to file a Suspicious Activity Report with the National Crime Agency, maintain your AML framework, report to the board on financial crime risk, oversee staff training, and act as the point of contact for the FCA on money laundering matters. We keep a full SAR decision log so the firm can evidence sound judgment under scrutiny.
2. 2Supporting your existing MLROIf you already have an MLRO in place, we provide co-sourced support rather than replacing them: second-line assurance over SAR decisions, cover during absence or between hires, framework and business-wide risk assessment reviews, board reporting, and staff training. This brings ex-FCA judgment alongside your in-house officer while they keep the MLRO role (and, in core and enhanced SM&CR firms, the SMF17 function).
3. 3You can outsource the function, not the responsibilityThe FCA is clear that outsourcing an MLRO does not transfer accountability. Under SYSC 8 the firm remains fully responsible for the outsourced activity, and its senior managers retain their obligations under the Senior Managers and Certification Regime. A credible outsourced MLRO arrangement therefore needs a documented service agreement, sufficient time allocation, genuine access to the firm's systems and management information, and board oversight, rather than just a name on a form.
4. 4When firms use outsourced or co-sourced supportWe are most often engaged by newly authorised firms that do not yet justify a full-time hire, firms bridging the gap between MLRO departures, and firms that want independent, ex-FCA judgment above their day-to-day AML operations. In every case we assess whether the role is genuinely outsourceable given the firm's size and risk profile. The FCA expects larger, higher-risk firms in particular to hold the function in-house.

Regulatory & Technical Expertise

Deep knowledge of financial crime regulations and practical implementation experience

Related specialist services

Financial crime work often sits inside a wider authorisation or crypto readiness programme rather than standing alone.

Related guidance

Sectors We Support

This service is available for firms across these regulated sectors

• Payment Services
• Consumer Credit
• Insurance Brokers
• Credit Brokers
• Wealth Management