AML/CFT Compliance and Regulatory Advice

For banks, financial institutions, designated non-financial businesses and professions, and virtual asset service providers, proceeds of crime legislation is felt most keenly as a compliance obligation. We advise regulated entities on building and maintaining the frameworks these regimes demand: (a) risk assessments, (b) customer (c) due diligence procedures, (d) record-keeping, (e) internal reporting lines and (f) the appointment and support of compliance officers and money laundering reporting officers.

A recurring concern for our clients is the reporting obligation itself: when a suspicious activity report must be filed, how to discharge that duty without falling foul of the prohibition on tipping-off, and how to manage the relationship with the Financial Intelligence Unit that follows. We advise on these judgment calls in real time, and we help institutions document their decisions defensibly.

We also act when scrutiny arrives — representing entities in supervisory examinations, responding to regulator enquiries and enforcement action, and designing remediation that restores good standing. Our aim is to keep our clients on the right side of a demanding and fast-moving regulatory environment, before problems arise rather than after.