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Protect Your Firm • Stay ProactiveFinancial Crime & AML Consultants
Financial-crime controls built around the risks in your customers, products and channels.
Specialist financial crime consultants for FCA-regulated firms. Our team of ex-regulators designs and implements AML frameworks, KYC controls, MLRO support and transaction monitoring programmes that meet FCA expectations and withstand supervisory scrutiny.
SERVICE OVERVIEW
Financial Crime and AML Support
Build financial-crime controls around the risks in your customers, products and channels.
MLROs, boards and regulated firms reviewing AML, sanctions, fraud or CDD controls. A risk-based financial-crime framework with ownership, testing and escalation.
Evidence we help you build
- Business-wide risk assessment
- CDD, KYC and sanctions procedures
- Monitoring and SARs framework
- MLRO reporting and control testing
Typical timeframe
Depends on scope
A consultancy phase builds, reviews or repairs the framework; a managed service then keeps it running. Fees and timing are agreed in writing in a statement of work before work starts.
Ideal for
- MLROs
- Boards
- Regulated firms reviewing AML, sanctions, fraud or CDD controls
Which control area needs review?
- Risk assessment
- CDD and KYC
- Monitoring and SARs
- Sanctions and fraud
How MEMA helps you
- AML consultant (project or advisory)
- Managed service (outsourced or co-sourced MLRO)
- Former regulators, Big 4 consultants and fintech specialists
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.
Former regulators
People who assessed financial-crime frameworks from the FCA's side of the table, and know which answers hold up
Big 4 consultants
Practitioners who have built and tested AML frameworks at scale, in banks and in payments firms
Fintech specialists
People who have run compliance inside fast-moving firms, where controls have to work at product speed
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.
- 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.
- 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.
- 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.
- 4Test whether it worksSample testing and control assurance against the framework, so weaknesses surface in your own review rather than in a supervisor's.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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
Build a risk-based AML framework
The control framework should be anchored in the firm's business-wide risk assessment.
- Risk assessment
- Assess customers, geography, products, services, delivery channels and transaction patterns.
- CDD and KYC
- Set proportionate onboarding, ongoing review, enhanced due diligence and sanctions controls.
- MLRO arrangements
- Ensure the nominated officer has seniority, authority, time, information and reporting access.
Operate and test the controls
Financial crime controls need evidence of operation, judgement and escalation.
- Monitoring and SARs
- Define alerts, investigations, internal reporting, decisions and National Crime Agency submissions.
- Training
- Use role-relevant scenarios and retain attendance, assessment and refresh evidence.
- Independent testing
- Use monitoring, audit, issue logs and MLRO reporting to challenge whether controls work.
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.
- 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.
- 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).
- 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.
- 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.
AML consultant or managed service: which fits?
The choice is less about price than about who does the recurring work. Under either model the firm stays accountable to the FCA for its financial crime controls.
AML consultant (project or advisory)
We build, review or fix something and hand it over: a risk assessment, a policy suite, a monitoring review or a remediation plan. Your own staff then operate it.
Fits when you already have a capable MLRO and team and the framework needs to be built, refreshed or tested.
Managed service (outsourced or co-sourced MLRO)
We perform part of the recurring function: acting as your MLRO where the role is not the SMF17 function, taking SAR decisions, running periodic reviews and reporting to the board.
Fits when you have no suitable MLRO, are bridging a departure, or want independent judgment above day-to-day operation.
Many firms use both in sequence: a consultancy phase to build or repair the framework, then a managed service to keep it running. The wider FCA compliance consultancy service can cover the rest of the compliance function alongside this work.
What a defensible AML framework looks like, and where we work
Supervisors test whether controls work in practice, using the Money Laundering Regulations, SYSC 6.3, the FCA's Financial Crime Guide and JMLSG guidance as reference points. A framework that holds up leaves this kind of evidence:
- A dated, approved business-wide risk assessment that visibly drives the level of customer due diligence
- Policies that match what staff actually do, and a record that staff were trained on them
- A named MLRO with the seniority, time and access to make independent SAR decisions, and a log of those decisions
- Monitoring and screening rules with a documented rationale, tested, with alert decisions that record why an alert was closed or escalated
- Independent testing results, with findings tracked to closure
- Management information that gives the board a true view of financial crime risk
Whether a firm is directly within scope of the Money Laundering Regulations 2017 or subject to financial crime obligations under the FCA Handbook, we confirm which regime applies at the start, because it determines what the framework must contain. For payment and e-money firms, consumer credit and wealth management, the same approach applies. Firms preparing an application can pair it with FCA authorisation support.
MEMA is based in London and supports firms throughout the UK, mostly remotely and on site where it helps. Every client has access to the MEMA client portal for the project plan, information requests, documents, messages, FCA correspondence and monthly updates. Led by ex-FCA regulators, with 100+ firms authorised and 10+ years of experience. For wider compliance support, see our FCA compliance consultants.
Regulatory & Technical Expertise
Deep knowledge of financial crime regulations and practical implementation experience
Money Laundering Regulations
Proceeds of Crime Act
Terrorism Act
Sanctions Regimes
FCA Handbook
JMLSG Guidance
UK Bribery Act
FCPA Compliance
A financial crime framework that satisfies the FCA and banking partners
The firm's customer base was growing faster than its anti-money laundering controls, and a banking partner had started asking hard questions. Without a defensible framework, it risked losing that relationship and falling short of FCA expectations.
A financial crime framework that passed the banking partner's due diligence and held up to FCA scrutiny.
Latest financial crime analysis
Source-led analysis of surveillance, transaction monitoring and fraud controls for regulated firms.
- Market-abuse surveillance controlsBoard-level lessons from the FCA fine imposed on Dinosaur Merchant Bank Limited.Read the analysis →
- Transaction monitoring systemsHow firms can design monitoring, escalation and assurance that stands up to scrutiny.Read the analysis →
- APP fraud preventionPractical controls for detecting and disrupting authorised push payment fraud.Read the analysis →
Related specialist services
Financial crime work often sits inside a wider authorisation or crypto readiness programme rather than standing alone.
- UK Cryptoasset Authorisation ReadinessCrypto-specific AML, sanctions, fraud, governance, custody, and application evidence support under the incoming FCA regime.
- FCA AuthorisationBroader permissions, threshold conditions, business plan, and application support for firms entering the UK regulatory perimeter.
Related guidance
Sectors We Support
This service is available for firms across these regulated sectors
Explore our other services
Support that sits alongside financial crime controls.
Frequently Asked Questions
Common questions about financial crime compliance
What AML controls does the FCA expect?
The FCA expects a risk-based approach to anti-money laundering under the Money Laundering Regulations 2017 (MLR 2017). This includes a documented business-wide risk assessment, customer due diligence (CDD) proportionate to risk, ongoing monitoring of business relationships and transactions, suspicious activity reporting (SARs) to the NCA, staff training and awareness programmes, and independent audit of AML systems and controls. The FCA assesses firms against these requirements during supervisory visits and through its financial crime data returns.
What is a business-wide risk assessment?
Regulation 18 of MLR 2017 requires firms to carry out a documented assessment of the money laundering and terrorist financing risks they face. The business-wide risk assessment (BWRA) must consider customer types, countries of operation, products and services offered, delivery channels, and transaction volumes. It must be kept up to date (most firms review it at least annually), approved by senior management, and made available to the FCA on request. The BWRA forms the foundation of a firm's entire AML programme and informs the level of CDD applied to different customer segments.
Does every firm need an MLRO?
Firms within scope of the Money Laundering Regulations must appoint a nominated officer to receive internal reports and decide on SARs to the National Crime Agency, 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. The MLRO must have sufficient seniority, resources, and authority to fulfil the role effectively. For smaller firms, the MLRO role can be combined with other senior management functions.
How often should AML training be delivered?
Regulation 24 of MLR 2017 requires firms to provide regular training to all relevant employees. The FCA expects AML training to be delivered at induction for new staff and refreshed regularly for all employees, and most firms refresh it at least annually. Training should be tailored to the specific risks and typologies relevant to the firm's business, cover current regulatory expectations and emerging threats, and include practical case studies. Records of training delivery and attendance must be maintained and made available to the FCA on request.
What does a financial crime consultant do?
A financial crime consultant designs, reviews and implements the controls firms need to prevent and detect money laundering, fraud, bribery and sanctions breaches. Day-to-day work includes drafting and updating the business-wide risk assessment, customer due diligence policies, transaction monitoring rules and MLRO procedures. Financial crime consultants also deliver staff training, conduct gap assessments against FCA expectations, assist with supervisory visits, and provide expert input when the FCA or NCA makes enquiries. MEMA's financial crime consultants are ex-regulators who have seen financial crime controls from both sides of the supervisory relationship.
Do I need a financial crime consultant?
Any FCA-authorised firm subject to the Money Laundering Regulations 2017 needs robust financial crime controls - the question is whether to build them in-house or use a financial crime consultant. Consultants are particularly valuable when a firm is setting up its AML framework for the first time, preparing for an FCA supervisory visit, responding to a skilled person review, or needs a gap assessment against current FCA expectations. Ongoing consultancy retainers are cost-effective for smaller firms that cannot justify a full-time financial crime specialist but still face the same regulatory obligations as larger institutions.
What is the difference between an MLRO and a financial crime consultant?
The MLRO (in core and enhanced SM&CR firms, the SMF17 function) is the individual responsible for oversight of the firm's compliance with the FCA's anti-money laundering rules, and usually also acts as the nominated officer who decides whether to report suspicions to the National Crime Agency. A financial crime consultant is an external adviser who supports the MLRO with the design, implementation and ongoing operation of the firm's controls. Many smaller firms appoint a senior manager as MLRO and engage a financial crime consultant to do the substantive work: drafting policies, running training, conducting monitoring and advising on complex CDD cases. The MLRO retains accountability; the consultant provides expertise and capacity.
Can I outsource my MLRO to a compliance consultant?
Yes. Firms within scope of the Money Laundering Regulations can appoint an external person as their MLRO (in core and enhanced SM&CR firms, the SMF17 function, which needs FCA approval), and this is common for smaller and newly authorised firms. But the FCA is clear that outsourcing the function does not outsource the responsibility: under SYSC 8 the firm remains accountable for the activity, and its senior managers keep their SM&CR obligations. A credible arrangement needs a documented agreement, adequate time, genuine access to the firm's systems and management information, and board oversight. MEMA provides both outsourced and co-sourced MLRO support led by ex-FCA regulators, with a full SAR decision log so the firm can evidence sound judgment.
How much do AML consulting services cost?
Fees depend on scope: the size and complexity of the firm, its products, customers and geographies, how much of the framework already exists, and whether you need a one-off deliverable or recurring support. They are agreed in writing in a statement of work before work starts, and clients can see the statement of work in the MEMA client portal.
What is the difference between an AML consultant and a managed service?
An AML consultant builds, reviews or repairs part of the framework, such as the risk assessment, policies or a monitoring review, and hands it over for your team to run. A managed service takes on part of the recurring function, for example acting as your outsourced MLRO (outside SMF17 roles) and reporting to the board. Many firms use the first to build the framework and the second to keep it running. Either way the firm remains accountable to the FCA.
Can you review our transaction monitoring and sanctions screening?
Yes. We review coverage against your risk assessment, rule and threshold calibration, the quality of alert decisions and whether the rationale is recorded well enough to show a supervisor, whichever system you use.
Practical review and remediation support
Test the framework against actual records
Our financial-crime reviews connect the business-wide risk assessment and client-risk method to onboarding, screening decisions, enhanced measures, source-of-funds evidence and ongoing monitoring. We distinguish current weaknesses from historic gaps and credit subsequent evidence.
What you receive: Design assessment, proportionate file testing, reconciled management responses and specific corrective actions with closure tests.
We agree whether MEMA is advising, implementing changes or providing independent assurance. Where roles could conflict, the scope and reviewer separation must address that before the work starts.
Strengthen Your Financial Crime Defences
Contact our financial crime experts to discuss your AML, fraud prevention, and sanctions compliance needs
Phone: 0330 133 0811
Email: contact@memaconsultants.com
