STAY COMPLIANT

Protect Your Firm • Stay Proactive

Financial 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

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