5 Circles LTD

Financial Institutions Operating System

Module Catalogue

Building blocks

Connected system

Fully adaptable

The full picture of what each module delivers, and how they work together. Modules are the building blocks of your FI Operating System. You choose the ones that fit your gaps; we deliver them as one connected system, not loose documents.

How to read this

  • • A module = one deliverable unit. Each card lists what you receive, and our role in it.
  • • Size = module count (1-15), mix = which modules you choose. Selection is made with us after exploration, gap-driven and dependency-checked.
  • • Effort scales with scope. The effort on each card is indicative for a full build; your quote is always a transparent hours band.
  • • Two roles. We Design & Deliver our own work product, or we Advise & Support a function that another department owns. Every card specifies which.

Our role, and its limits

We design, build and support. We do not carry regulatory liability for your operation, and we do not own functions that belong to your Risk, Finance, IT or Board. Where a module is Design & Deliver, we stand behind the design; the regulated outcome still stays with your MLRO and board. Where a module is Advise & Support, your function owns the duty and the outcome, and we bring the expertise, methodology and review. We would rather tell you plainly where our responsibility ends: that is what makes the rest of this credible.

1

The system at a glance

Module Function Role & Owner
Client Success & Commercial
1. Commercial Intelligence & Profiling Client Success & Commercial Design & Deliver
2. Account Management & Retention Client Success & Commercial Design & Deliver
3. Pricing Strategy Client Success & Commercial Design & Deliver
4. Sales & Introducer Playbooks Client Success & Commercial Design & Deliver
Operations & Automation
5. Onboarding & Compliance Workflows Operations & Automation Design & Deliver
6. Safeguarding & Client Funds Operations & Automation Advise & Support (Risk / COO / Finance)
7. Regulatory Reporting Operations & Automation Advise & Support (CFO / Risk)
8. IT & Information Security Operations & Automation Advise & Support (CTO / CISO)
Compliance & Risk
9. Sanctions Screening Programme Compliance & Risk Design & Deliver
10. AML Programme Compliance & Risk Design & Deliver
11. Client Due Diligence Suite Compliance & Risk Design & Deliver
12. Enhanced Due Diligence Compliance & Risk Design & Deliver
13. Transaction Monitoring Compliance & Risk Design & Deliver
14. Governance & Accountability Compliance & Risk Advise & Support (Board / MLRO)
15. Inspection Readiness Compliance & Risk Design & Deliver
2

Client Success & Commercial

1. Commercial Intelligence & Profiling

Design & Deliver

Know exactly who you are to a bank, and what you can become.

What's delivered:

  • •Typology-matched business profile (from our 22-profile matrix)
  • •Commercial potential scoring (revenue & banking/payment estimate)
  • •Banking and payment reality map for your model and market
  • •Red-flag pre-check before you approach a bank or partner
  • •Positioning brief for investor and partner conversations
Works with: Sales Playbooks, Account Management Effort: ~9-26h

2. Account Management & Retention

Design & Deliver

Turn one-off clients into long-term revenue.

What's delivered:

  • •Account management framework (onboarding through QBR)
  • •Retention automation (scheduled triggers: reviews, milestones, follow-ups)
  • •Client health monitoring (usage and growth over 3, 6 and 12 months)
  • •Monthly account report and quarterly business review pack
  • •Escalation and intervention playbook for at-risk accounts
Works with: Commercial Intel, Regulatory Reporting Effort: ~9-26h

3. Pricing Strategy

Design & Deliver

Price with confidence, protect your margin.

What's delivered:

  • •Pricing model designed to your products and segments
  • •Margin analysis per product line
  • •Negotiation guardrails and discount framework
  • •Competitive positioning brief
  • •Pricing review cadence
Works with: Commercial Intel, Sales Playbooks Effort: ~9-26h

4. Sales & Introducer Playbooks

Design & Deliver

A repeatable route to new business and partners.

What's delivered:

  • •Introducer onboarding and due diligence workflow
  • •Referral pipeline management
  • •Partner due diligence workflows
  • •Disclosure and compensation terms template
  • •Acquisition SOP suite
Works with: Commercial Intel, Account Mgmt, CDD Suite Effort: ~9-26h
3

Operations & Automation

5. Onboarding & Compliance Workflows

Design & Deliver

The daily engine that runs your operation, consistently.

What's delivered:

  • •Client onboarding workflow, end to end
  • •Agent-performed onboarding workflow (responsibility mapped)
  • •Screening escalation workflow
  • •Periodic review and termination/exit workflows
  • •Compliance training workflow
Works with: CDD Suite, Sanctions, AML Programme Effort: ~14-26h

6. Safeguarding & Client Funds

Advise & Support

Client money, protected and provable.

Owner: Risk / COO / Finance (we advise; your function owns duty & outcome)

What's delivered:

  • •Client-fund segregation account structure
  • •Daily reconciliation process with evidence trail
  • •Safeguarding governance
  • •Approved-banks schema
  • •Trust deed brief (prepared with your external advisor)
Works with: Governance, Regulatory Reporting Effort: ~9-17h

7. Regulatory Reporting

Advise & Support

Never miss a filing, never surprise the board.

Owner: CFO / Risk (we advise; your function owns filings & outcome)

What's delivered:

  • •Regulatory reporting calendar with owners and deadlines
  • •Programme charter
  • •Board reporting pack
  • •Findings-closure KPI (tracks that fixes actually land)
  • •Regulatory returns preparation checklist
Works with: Governance, Inspection Readiness Effort: ~9-17h

8. IT & Information Security

Advise & Support

A secure, resilient operating base.

Owner: CTO / CISO (we advise; your function owns security posture)

What's delivered:

  • •PSD2 SCA/CSC design
  • •Information security policy (finalised with external advisor)
  • •Business continuity and disaster recovery plan
  • •Incident reporting procedure
  • •Access and change-management controls
Works with: Governance, Regulatory Reporting Effort: ~9-17h
4

Compliance & Risk

In collaboration with your compliance officer: we deliver the design and scoping to best practice; ownership and daily execution stay with your team and your MLRO.

9. Sanctions Screening Programme

Design & Deliver

Screen every client and transaction to a defensible standard.

What's delivered:

  • •Screening programme design
  • •Severity-to-cadence map (critical risks screened in real time)
  • •Near-miss handling path
  • •Screening KPI set
  • •Screening policy and procedure
Works with: AML, CDD Suite, TM Effort: ~19-35h

10. AML Programme

Design & Deliver

One coherent AML/CTF programme, not scattered policies.

What's delivered:

  • •AML/CTF programme blueprint
  • •CDD standards and file remediation criteria
  • •Risk rating framework
  • •Know-your-business (KYB) process
  • •Agent oversight programme
Works with: Sanctions, CDD, EDD, TM Effort: ~19-35h

11. Client Due Diligence Suite

Design & Deliver

Onboard clients, partners and agents the right way, every time.

What's delivered:

  • •Client onboarding due diligence process
  • •Partner and correspondent due diligence
  • •Agent-network due diligence
  • •Re-due-diligence cadence
  • •Document request stacks (universal, industry & conditional)
Works with: AML Programme, EDD Effort: ~9-17h

12. Enhanced Due Diligence

Design & Deliver

Higher-risk clients, handled to a higher standard.

What's delivered:

  • •EDD trigger matrix
  • •Enhanced measures playbook
  • •Escalation paths
  • •Corridor EDD flows (agent and MSB routes)
  • •EDD policy and procedure
Works with: CDD Suite, AML Programme Effort: ~9-17h

13. Transaction Monitoring

Design & Deliver

Catch what matters, clear the noise.

What's delivered:

  • •Transaction monitoring scenario catalogue
  • •Tuning loop with detection metrics
  • •Alert disposition SOP
  • •SAR/STR filing process and SLA
  • •Transaction schema mapping (integration ready)
Works with: AML Programme, Sanctions Effort: ~14-26h

14. Governance & Accountability

Advise & Support

Clear ownership, board-level oversight, no surprises.

Owner: Board / MLRO (we design framework; board owns it)

What's delivered:

  • •Three-lines-of-defence design
  • •MLRO charter
  • •Board risk-appetite framework
  • •Board reporting cadence
  • •Compliance staffing case
Works with: Every module (accountability backbone) Effort: ~19-35h

15. Inspection Readiness

Design & Deliver

Ready for the regulator before you are asked.

What's delivered:

  • •Inspection survival kit
  • •Remediation programme blueprint
  • •Accountability and enforcement mechanics
  • •Mock inspection protocol
  • •Regulator correspondence pack
Works with: Sanctions, AML, CDD Suite, EDD, TM Effort: ~9-17h
5

How modules work together

They are not a menu of loose documents. They form one system, organized in four distinct operational layers:

1. Governance sets ownership Governance & Accountability. Nothing else holds without it.
2. Programmes define the rules Sanctions, AML, CDD, EDD.
3. Monitoring proves compliance Transaction Monitoring proves rules are applied.
4. Workflows execute daily Onboarding & Compliance Workflows run controls; Inspection Readiness proves it under pressure.

Natural build order: roots first, then depth

  1. 1 Roots: Governance & Accountability, Sanctions Screening Programme.
  2. 2 Build on roots: AML Programme (needs screening baseline), then Client Due Diligence, EDD, and Transaction Monitoring.
  3. 3 Make it run: Onboarding & Compliance Workflows (executes the programme controls).
  4. 4 Prove it: Regulatory Reporting and Inspection Readiness.
  5. • Alongside: Commercial and operations modules (intelligence, account management, pricing, sales, safeguarding, IT security) run in parallel and feed the same system.

Three example combinations

Size Example path Why it works
Starter (1-3) Sanctions Screening + AML Programme + Account Management & Retention Stabilise the two critical pillars, and start growing revenue in parallel.
Professional (4-7) Sanctions + AML + CDD + Transaction Monitoring + Onboarding Workflows + Governance A complete compliance engine that runs daily.
Enterprise (8-15) Professional + EDD + Safeguarding + Regulatory Reporting + IT Security + Inspection Readiness The full operating system, regulator-ready.
Where the enforcement shadow plugs in: The optional retainer keeps the whole system live. It runs regular 360° assessments across every module, tracks closure, and escalates slippage, so the system stays enforced after handover.
6

What you provide

  • •Access: interviews (CEO, MLRO, compliance, board, ops) & on-site observation.
  • •Evidence: sampled files, registers and system access for modules in scope.
  • •Named owner: a dedicated owner on your side for accountability.
  • •Owning functions: for Advise & Support modules, Risk, Finance, IT & Board stay in the room.
7

Start here

  1. 1.Exploration (4,500 EUR): 2-3 weeks. We find facts and recommend your modules.
  2. 2.Pick your size and modules: gap-driven and dependency-checked.
  3. 3.We build the system: you run it, and we assess weekly that it runs.