AMS takes over the AML function of fintech, payment and crypto companies — from drafting the AML policy and KYC procedures to acting as your outsourced AML Officer / MLRO. One team covers policies, independent audits, staff training, transaction monitoring and regulatory reporting, so your compliance framework works as one system.
Full-cycle AML compliance outsourcing for regulated businesses
Building an in-house AML function takes time and resources. You need a qualified compliance officer, documented procedures, monitoring tools and ongoing training. With outsourced AML compliance services, AMS brings these elements together in one managed setup, scaled to the size and risk profile of your business.
We provide outsourced AML services to obliged entities, including payment institutions, e-money institutions, crypto-asset service providers (CASPs), investment firms and corporate service providers. Our team combines AML compliance with licensing experience, so we understand what supervisors expect both during CASP, PI and EMI authorisation and in ongoing operations.
We manage the full AML programme in one place: policies aligned with your business model, practical KYC and due diligence procedures, an experienced AML Officer where required, and timely regulatory reporting.
AML services you can outsource
Where an AML Officer or Money Laundering Reporting Officer is required, AMS can appoint an experienced specialist to oversee the AML function. The role can cover internal controls, escalation procedures, suspicious activity reporting and contact with the relevant authorities. This gives you a working AML function without building the role in-house.
AML Officer and MLROOur AML specialists support the questions that come up during normal operations: client risk classification, enhanced due diligence, unusual transactions and changes in regulatory requirements. We help your team decide how to proceed and document the reasoning behind each decision.
AML advisory servicesWe draft the AML framework around how your business actually works and where its main risks sit. The documentation can cover the enterprise risk assessment, customer acceptance rules, KYC and due diligence, transaction monitoring, escalation and reporting. We also help translate the written framework into working internal processes.
AML policy developmentWe review both the written AML framework and how the controls work in day-to-day operations. The result is a structured gap analysis showing what is missing, what needs improvement and which issues should be addressed first. The review can be used to prepare for supervisory, banking or internal scrutiny.
Independent AML auditWe assist with suspicious activity reports and other AML-related filings, from deciding whether a report is required to preparing the submission and supporting rationale. We also keep the reporting trail documented so each decision can be traced later.
SAR filing & reportingAML training for employees, from onboarding for client-facing teams to more specialised sessions for compliance staff. Training is adapted to the roles, risks and situations your employees actually encounter, with records and certificates of completion where required.
AML employee trainingWe help select, implement and configure AML tools for screening, transaction monitoring and case management. The technology is matched to your transaction volumes, risk profile and internal procedures, so alerts feed into a clear review, escalation and documentation process.
AML automation toolsSend us your business model and the services you need. We will prepare a tailored proposal with the scope, timeline and AML compliance services cost for your setup.
Request a cost estimateAML obligations extend well beyond banks. Financial institutions are generally in scope by definition, while a range of professional and commercial businesses may also qualify as obliged entities depending on their activities and jurisdiction.
PIs and EMIs operate inside the AML framework from the outset, with formal KYC, risk assessment, monitoring and reporting obligations.
CASPs, VASPs and investment firms are obliged entities and need AML controls proportionate to their clients, products, transactions and risk exposure.
Corporate service providers, accountants and certain other professional service firms can also fall within AML rules, even without a financial licence.
Currency exchange businesses and real estate intermediaries are also within the AML perimeter where the relevant national rules apply.
Being an obliged entity does not mean every business needs the same AML setup. The framework should be proportionate to the actual risks of your clients, products and transactions — a small corporate services firm and a crypto exchange should not be built around the same level of monitoring and due diligence.
Send us your business model and jurisdiction. We’ll identify whether you are an obliged entity, which AML requirements apply and what level of compliance is proportionate to your business.
REQUEST AN AML ASSESSMENTWe start with what already exists: your licence obligations, current policies and working procedures. You receive a written gap analysis showing what is missing, outdated or creating unnecessary exposure.
We draft or update the AML policy, risk assessment and internal procedures so they reflect your business model, risk profile and regulatory requirements.
Where required, we provide an outsourced AML Officer or MLRO to support the ongoing function, coordinate key compliance tasks and keep responsibilities clearly assigned.
Screening, transaction monitoring and reporting tools are configured around the AML framework and your actual transaction volumes and risk patterns.
Monitoring, SAR filing, staff training, periodic audits and updates when the rules change. AML compliance becomes a managed process with clear responsibilities and a working calendar.
Our AML team works alongside CASP, PI and EMI licensing projects, so we understand how compliance is assessed during authorisation and what supervisors expect once the business is operating.
We do not stop at policies. The setup can include the responsible officer, procedures, monitoring tools, reporting, training and a compliance calendar built to work together in day-to-day operations.
We work with transaction monitoring, Travel Rule processes, crypto-asset flows and the regulatory requirements specific to CASPs, payment institutions and e-money businesses.
The same team can support the business before authorisation, during the regulatory review and after launch, so the AML framework does not have to be rebuilt when the company moves into operations.
We do not force every client into the same policy pack. The framework is built around your business model, customer profile, transaction volumes and actual risk exposure.
AML advisory, outsourced key roles, training, audits, reporting and technology support can be coordinated through one team instead of several separate providers.
Send us your current policies and a short description of how compliance works today. We’ll identify the gaps and tell you which parts are worth updating or outsourcing.
Request an AML reviewCrypto businesses need AML controls that cover both the customer relationship and the movement of crypto-assets. For CASPs and VASPs regulated under MiCA, this means adding crypto-specific controls to the standard AML framework.
Crypto AML requires visibility into wallet exposure and transaction history. Screening and on-chain monitoring help identify higher-risk addresses, unusual flows and activity that may require further review.
CASPs and VASPs need procedures for collecting, checking and transmitting the information required under the Travel Rule. The process should fit the actual transaction flow rather than sit separately from the rest of the AML framework.
The underlying standard is set at international level — see the FATF materials on virtual assets and VASPs.
Traditional AML procedures are not always enough for crypto activity. Policies need to address wallet risk, source of crypto-assets, higher-risk transaction patterns and clear escalation routes for cases that need additional review.
For CASPs the framework also has to fit the licensing regime — the full text of the EU rules is published on EUR-Lex (Regulation (EU) 2023/1114, MiCA).
AMS can review an existing framework, update policies and procedures, help configure monitoring tools or carry out an independent crypto AML audit before regulatory, banking or internal review.
If the company is not licensed yet, AML work runs alongside crypto licensing, so the framework described in the application is the one that operates after approval.
Yes. Companies regularly outsource AML compliance in whole or in part: policy drafting, KYC and due diligence procedures, transaction monitoring, staff training, reporting support and, where permitted, parts of the AML compliance officer function. The exact scope depends on the applicable law and the type of regulated entity.
Outsourcing does not transfer regulatory accountability away from the obliged entity. The company still needs appropriate oversight of the outsourced work and a clear record of how AML responsibilities are managed.
The MLRO owns the AML agenda inside the company: keeps procedures up to date, reviews escalated cases, decides whether a suspicious activity report is required and files it, and acts as the contact point for the regulator and the FIU. An outsourced MLRO delivers the same role as a service — an experienced specialist formally appointed to the position, with documented decisions, but without a full-time hire.
What can be outsourced depends on the jurisdiction and the regulated activity. The company itself still remains responsible for proper oversight and for being able to show how the outsourced AML work is organised and controlled.
AML compliance services can cover either the whole operating framework or one specific part of it. Typical work includes AML policies, enterprise risk assessment, KYC/CDD and EDD procedures, sanctions and PEP screening, transaction monitoring, SAR/STR reporting, staff training, independent AML audits and support with compliance technology.
The scope should be built around the actual business model. Some companies outsource the full AML function; others need only a policy update, audit, outsourced MLRO or ongoing advisory support.
KYC is the customer-facing part of the wider AML system. It covers identifying and verifying clients, understanding who they are, assessing their risk and deciding what level of due diligence is appropriate.
AML is broader. It also includes the company-wide risk framework, internal policies, transaction monitoring, escalation, reporting, training and ongoing controls. In practice, KYC decisions made at onboarding need to feed into what happens later during the client relationship.
Usually, yes. The risks in crypto are different enough that standard AML procedures often need an extra layer. CASPs may need wallet analytics, on-chain monitoring, controls for self-hosted addresses and Travel Rule workflows.
Existing AML policies can still provide the base, but the controls should be rebuilt around the way the crypto business actually moves assets, serves clients and manages risk.
It depends on what already exists and how broad the scope is. A focused project, such as an AML policy update or independent audit, can usually be completed faster than building an entire AML function from the ground up.
We start with a gap review to establish what can be retained, what needs to be replaced and which operational elements are still missing. That gives the client a realistic scope and timeline before the full implementation begins.
Because the existence of AML documents does not show whether the framework still matches the business. Products change, customer profiles evolve, transaction volumes grow and day-to-day procedures can move away from what the written policy says.
An independent AML audit compares the documented framework with current requirements and actual operations. The result shows where policies, controls or working practices need to be updated before those gaps surface during supervisory, banking or internal review.