Applicant questions
- - Who are the customers, investors, counterparties, introducers, and beneficial owners?
- - How will the firm perform onboarding, screening, monitoring, escalation, and suspicious-activity handling?
- - Which countries, products, payments, and distribution channels raise financial-crime risk?
Why regulators ask
- - AML/CFT evidence shows whether the applicant can prevent misuse of the regulated business.
- - Regulators expect financial-crime controls to match products, clients, jurisdictions, and distribution channels.
- - A generic AML manual without workflows can create major follow-up questions.
What good looks like
- - Risk assessment, onboarding workflow, sanctions screening, transaction/investor monitoring, and escalation steps align.
- - Responsibilities are assigned to named roles and backed by training and testing.
- - High-risk clients, introducers, and cross-border flows have enhanced controls.
Documents to prepare
- - AML/CFT risk assessment.
- - Customer due diligence and enhanced due diligence procedures.
- - Sanctions and politically exposed person screening workflow.
- - Suspicious activity escalation and reporting process.
- - Training, testing, and annual review plan.
Red flags
- - The AML policy is copied from a generic template and ignores the business model.
- - Introducers, private funds, cross-border investors, or payment flows are not mapped.
- - No one owns sanctions alerts or escalation decisions.
Build steps
- 1. Start with client, investor, counterparty, product, and country risk.
- 2. Turn the risk assessment into onboarding and monitoring steps.
- 3. Document ownership, training, testing, and adviser questions.
Disclaimer
Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.