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.
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 |
Client Success & Commercial
1. Commercial Intelligence & Profiling
Design & DeliverKnow 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
2. Account Management & Retention
Design & DeliverTurn 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
3. Pricing Strategy
Design & DeliverPrice 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
4. Sales & Introducer Playbooks
Design & DeliverA 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
Operations & Automation
5. Onboarding & Compliance Workflows
Design & DeliverThe 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
6. Safeguarding & Client Funds
Advise & SupportClient 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)
7. Regulatory Reporting
Advise & SupportNever 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
8. IT & Information Security
Advise & SupportA 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
Compliance & Risk
9. Sanctions Screening Programme
Design & DeliverScreen 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
10. AML Programme
Design & DeliverOne 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
11. Client Due Diligence Suite
Design & DeliverOnboard 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)
12. Enhanced Due Diligence
Design & DeliverHigher-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
13. Transaction Monitoring
Design & DeliverCatch 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)
14. Governance & Accountability
Advise & SupportClear 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
15. Inspection Readiness
Design & DeliverReady 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
How modules work together
They are not a menu of loose documents. They form one system, organized in four distinct operational layers:
Natural build order: roots first, then depth
- 1 Roots: Governance & Accountability, Sanctions Screening Programme.
- 2 Build on roots: AML Programme (needs screening baseline), then Client Due Diligence, EDD, and Transaction Monitoring.
- 3 Make it run: Onboarding & Compliance Workflows (executes the programme controls).
- 4 Prove it: Regulatory Reporting and Inspection Readiness.
- • 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. |
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.
Start here
- 1.Exploration (4,500 EUR): 2-3 weeks. We find facts and recommend your modules.
- 2.Pick your size and modules: gap-driven and dependency-checked.
- 3.We build the system: you run it, and we assess weekly that it runs.