AML for FinTech

Launching payment business from scratch.
EMI, PI, MSO, MSB licenses

Measures aimed at ensuring anti-money laundering (AML) through a payment platform are among the key requirements of regulators during licensing and subsequent operations. The SBSB team recommends developing and implementing internal AML policies before launching the payment business and conducting regular AML audits after its launch.

AML Audit for FinTech Projects by SBSB Specialists

A comprehensive AML check is an integral part of risk management in any FinTech project. Specialists evaluate and verify AML/CFT systems and procedures to prevent money laundering and combat terrorism financing. The audit helps assess how well a company’s activities align with the standards set by FATF (Financial Action Task Force on Money Laundering). Recommendations developed by this intergovernmental organization are mandatory for financial service providers.

Failure to comply with FATF requirements can lead to significant fines, imprisonment, and license revocation. Penalties (temporary bans, liquidation, judicial supervision, imprisonment) are also stipulated in the Fifth (AMLD5 EU) and Sixth (AMLD6 EU) Directives, which apply within the member states of the European Union.

The team of SBSB experts is prepared to provide guidance, develop and implement internal and external policies, and conduct AML audits to verify compliance with specific regulator rules. This examination allows financial institutions to identify potential threats to system stability, reduce potential risks of financial crimes, and avoid issues with law enforcement.

Stages of Conducting AML Audit

The step-by-step algorithm for conducting an AML audit looks as follows:

Company Activity Analysis. During the audit, specialists review document workflows, check systems for monitoring, analyze employee operations, evaluate the organization’s internal control system, and assess data verification and customer identification systems.

Reporting. Following the procedure, our lawyers prepare a report with recommendations, enabling you to improve and enhance the platform without turning it into a site for money laundering.

Development of AML Policies and Procedures. If necessary, SBSB lawyers design a set of specialized AML policies and procedures tailored to your organization’s specificities. We can also prepare client identification and verification processes to gather as much information about users as possible.

Testing. This stage helps evaluate how effectively the organization’s compliance program aligns with AML policies. Subsequently, deficiencies are addressed, and improvements are made based on the developed recommendations. 

Training Program. One of the final stages of an AML audit could involve educating your company’s employees. Through training sessions, employees can be informed about system enhancements, regulatory requirements, and updates in legislative acts.

Advantages of AML Audit for Payment Organizations 

Conducting this check brings several advantages to FinTech projects, including:

  • Legislative Compliance. An AML audit demonstrates that the organization complies with laws and regulatory acts.
  • Risk Minimization. SBSB Fintech Lawyers recommend conducting regular AML audits to identify vulnerabilities and weaknesses in control systems to prevent financial crimes.
  • Enhanced Reputation. Conducting an AML audit increases trust from partners, investors, clients, and regulators, as the company adheres to requirements and standards.
  • Avoidance of Fines and Penalties. An AML audit helps prevent the laundering of criminal proceeds, avoiding penalties.
  • Improving Internal Processes. Timely independent verification assists in optimizing internal processes and AML-related procedures.

Cost of an AML Audit

The cost of the examination depends on various factors, including the range of services the company offers, the number of clients, and the volume of work.

Why Choose SBSB for AML Policy Development and AML Audit 

If you need to develop internal AML policies or conduct an AML audit to track, prevent, and manage risks, turn to SBSB Fintech Lawyers. Since 2013, we have been involved in launching and supporting FinTech projects. We provide individual solutions to each client because every company’s business model is unique.

Contact us to discover how SBSB can assist your FinTech company!

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Ivan Nevzorov

Head of Legal

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