Service
Compliance & AML Advisory
Regulation moves faster than internal policy documents do. An AML programme that was compliant at licensing can quietly fall behind a regulator's current expectations within a year.
We review an operator's existing AML/CFT and KYC framework against the current requirements of its licensing jurisdiction, and identify the gaps that would surface in a regulator audit before the regulator finds them.
Where an operator has no in-house compliance officer, or is between hires, we provide interim advisory support — reviewing transaction monitoring rules, customer due diligence procedures, and reporting obligations without taking on a role that belongs to a licensed, accountable function.
What we do
- Gap analysis of existing AML/CFT policies against current jurisdictional requirements
- Review of KYC and customer due diligence procedures, including enhanced due diligence triggers
- Transaction monitoring rule review and escalation workflow assessment
- Support ahead of, and during, a regulator audit or thematic review
- Interim advisory support while an operator recruits a permanent compliance officer
- Staff training materials on AML/CFT obligations, tailored to the operator's licence
Who this is for
- Licensed operators preparing for a scheduled regulator audit
- Operators whose compliance officer has left and who need continuity without a compliance gap
- Groups that inherited an AML programme through acquisition and need it independently reviewed
Relevant for these jurisdictions
Jurisdiction
United Kingdom
The UK Gambling Commission (UKGC) operates one of the most demanding licensing regimes in the sector, combining a strict fit-and-proper test with an active enforcement record — a UK licence signals credibility, but it is also the jurisdiction where preparation gaps are least forgiven.
Jurisdiction
Malta
Malta remains one of the most established EU-based licensing jurisdictions for iGaming, with a single-licence structure covering both B2C and B2B activity through the Malta Gaming Authority — but its reputation for maturity comes with a correspondingly thorough fit-and-proper and AML review.
Jurisdiction
Curaçao
Curaçao replaced its long-standing master licence system with the Landsverordening Openbare Kansspelen (LOK) on 24 December 2024, moving licensing authority to a single regulator and materially raising the documentation bar for new and existing operators alike.
Talk through your situation
A short call is usually enough to tell whether this is the right service for where you are.