Regulators expectations for a risk based approach in AML

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When entrepreneurs from Europe, Asia and the CIS countries come to me for a consultation, almost always the same combination appears in their questions: where to register the company, how to obtain the required financial license and how to design AML so that regulators trust it and compliance doesn’t strangle the business.

Over the years that I have been leading COREDO, our team has gone with clients through the full cycle, from the idea of entering the EU or Singapore to a licensed and sustainable financial institution with a functioning risk-based AML model. In this article I want not just to list COREDO’s services, but to show how I think about the strategy of an international business structure and why the integration of registration, licensing and AML gives an entrepreneur a strategic advantage.

Logic of an international business structure

Illustration for the section 'Logic of an international business structure' in the article 'Risk-based approach in AML: regulators' expectations'
I always start the conversation not with jurisdictions, but with three questions:

  1. What is your target market and product (fintech, forex, crypto, payments, B2B services)?
  2. Which regulators and banks should trust you in 1–3 years?
  3. How ready are you for formalization and transparency – from KYC to regular reporting?

The answers determine:

  • where to register the head company (ES, UK, Czechia, Cyprus, Estonia, Singapore, Dubai, etc.);
  • where to obtain financial licenses (payment, EMI, forex, investment, crypto licenses);
  • how deeply to build the AML function and risk-based approach from the outset.
Many want to “quickly open a company and then deal with the license and AML later.” My experience at COREDO has shown: such a sequence almost always leads to wasted time, and sometimes to account freezes.

Registration of legal entities

Illustration for the “Registration of legal entities” section in the article “Risk-based approach in AML regulator expectations”
The COREDO team has for many years been registering legal entities in the EU, Asia and the CIS: both individual companies and entire holding structures. It may seem like a basic service, but it is here that the architecture of the future model is laid down:

  • tax consequences;
  • substance requirements (office, employees, directors);
  • potential regulatory requirements when licensing;
  • the banks’ attitude toward your jurisdiction and ownership structure.

Which areas I cover

  • Legal form
    For fintech and payment solutions, forms such as private limited / s.r.o. / OÜ and their equivalents are most often chosen, with a clear division of liability and a transparent capital structure.
  • Role of particular jurisdictions
    Czechia and Slovakia are convenient for operational centres and local activities in the EU.
    Cyprus, Estonia, Latvia, Lithuania, Poland are often used for financial services, IT, payment solutions and licensed activities.
    United Kingdom: a good platform for international B2B‑services and financial infrastructure, especially in combination with licensing.
    Singapore and Dubai: key points for entering the markets of Asia and the Middle East.
  • Practical setup of the process
    The COREDO team takes on the preparation of corporate documents, interaction with registration authorities, support for opening bank and EMI accounts, obtaining information about beneficiaries and their proper disclosure.
Here it’s important not merely to ‘register a company’, but to do so with the future license, AML obligations and banks’ KYC structure requirements in mind.

Financial licenses: how to build a strategy

Illustration for the section «Financial licenses: how to build a strategy» in the article «Risk-based approach in AML: regulators' expectations»
obtaining a financial license, one of the most challenging stages. This concerns:

  • payment and electronic money (PI/EMI, payment institutions);
  • forex and investment services;
  • crypto and VASP licenses;
  • specialized authorizations for asset management.

COREDO focuses on licenses in EU jurisdictions (Czechia, Cyprus, Lithuania, Latvia, Poland, Germany, France, Switzerland, etc.), as well as in the United Kingdom, Singapore and a number of other countries.

Why Licensing without AML does not work

Regulators have long looked not only at capital and the business plan, but also at:
  • risk-based AML model;
  • real governance (directors, MLRO, internal controllers);
  • the KYC/KYB system, transaction monitoring;
  • the quality of internal policies and procedures.
That is why at COREDO licensing is always paired with AML consulting and the development of a compliance framework.
One typical case: an entrepreneur planned a crypto license in one of the EU countries and came with a minimal set of documents. The COREDO team developed a full package for the client: a KYC/KYB policy, client risk-scoring, a procedure for transaction monitoring and reporting to the financial intelligence unit, and also trained the client’s future compliance team. As a result, the regulator accepted the documentation on the first round of requests: without lengthy revisions.

AML and the risk-based approach in practice

Illustration for the section «AML and the risk-based approach in practice» in the article «Risk-based approach in AML: regulators' expectations»
In AML regulation, the risk-based approach (an approach based on risk assessment) has long been key. EU regulators, the UK, Singapore and other jurisdictions expect that:

  • you understand your own risk profile (countries, products, clients, distribution channels);
  • you have a formalized methodology for assessing risks;
  • the compliance function’s resources are proportionate to actual risks;
  • policies and procedures not only exist, but are applied.
Here it’s appropriate to incorporate the thought I often tell clients: I appreciate your detailed request, but I need to clarify my role and limitations. In the case of regulators the situation is mirrored: they need to understand where the boundaries of your business model are, how you yourself see the risks and where you draw the red lines. The more precisely you articulate these frameworks in your documents and procedures, the higher the level of trust.

How COREDO builds the AML framework

AML consulting at COREDO: not about “writing a policy just for the sake of a checkbox”. A typical project includes:

  • Enterprise-wide risk assessment (EWRA) – a comprehensive risk assessment of the company taking into account countries, client types, products and channels.
  • Development of AML/CFT policies and procedures tied to the requirements of the specific regulator (for example, in the EU: taking into account AMLD directives, local laws and supervisory guidelines).
  • Establishing processes:
    • client identification and verification (KYC/KYB);
    • classification by risk levels;
    • transaction monitoring and detection of suspicious activity;
    • internal investigations and filing reports with the financial intelligence unit.
  • Employee training and setting up regular knowledge updates.
  • Support in dialogue with regulators and banks.
COREDO’s experience confirms: companies that truly live by a risk-based AML model gain more stable relationships with banks and fewer surprises such as account blocks and inquiries.

Legal and operational support after launch

Illustration for the section “Legal and operational support after launch” in the article “Risk-based approach in AML expectations of regulators”

Many believe that the main difficulty is registration and licensing. In fact, the main risks begin after entering the market.

COREDO was originally created as a company for long-term business support, not just for a “launch”. Today we cover the entire cycle:

  • Legal services and protection: from the contractual framework to corporate changes and disputes with counterparties.
  • Legal outsourcing – when it is uneconomical for a company to keep an in‑house legal department, but regular support is required in several jurisdictions.
  • Legal support for financial institutions and resolution of disputes with banks and payment service providers.
  • Registration and protection of trademarks in the EU, the UK and other countries, often in connection with market entry and licensing.
  • Accounting outsourcing and financial reporting in accordance with the requirements of the jurisdiction of registration.
For the client this means a single point of responsibility: from corporate law and the contract with a partner to responding to a regulator’s or a bank’s request.

Comprehensive project at COREDO: from idea to business

To make it clearer how I organize the work, I will present a typical scenario of a comprehensive project.

Diagnostics and strategy

  • Analysis of the business model, geography, and target audience.
  • Determining target jurisdictions for registration and licenses (EU, UK, Singapore, Dubai, selected CIS countries).
  • Map of regulatory requirements, expectations regarding AML and banking compliance practices.
Result, strategic structure diagram: parent company, licensable entities, auxiliary service companies.

Registration of legal entities

  • Choosing company forms and names, preparing articles of association and corporate agreements.
  • Registration in the chosen countries (for example, a parent structure in the EU, an operational fintech center in one of the jurisdictions with a developed regulatory framework).
  • Support for account openings (banks, EMIs, payment systems).

Stage 3. Business licensing

  • Preparation of a business plan and financial model in accordance with regulator requirements.
  • Development of internal policies (including AML/CFT, risk management, IT security if necessary).
  • Formation of the key persons team (directors, MLRO, compliance officers), preparation of their profiles and job descriptions.
  • Communication with the regulator at all stages.
The solution developed at COREDO at this stage typically already accounts for future market changes and potential tightening of AML requirements.

Building the AML function and operations

  • Implementation of KYC/KYB procedures and risk-scoring.
  • Setting up transaction monitoring, sometimes using third-party AML platforms, sometimes through the client’s internal solutions.
  • Incident management procedures, case management for suspicious transactions.
  • Staff training and testing procedures using real scenarios.
The COREDO team does not just write documents, but checks how they operate in the operational reality of the business.

Long-term support of the site

  • Updating policies and procedures taking into account regulatory changes.
  • Support during regulator inspections and audits.
  • Legal support for corporate changes and transactions.
  • Registration of new trademarks, entry into additional markets, adaptation of the structure.
This approach turns consulting from a one-time service into an instrument of strategic risk management and growth.

What to consider when choosing a partner

Entrepreneurs often ask me how to evaluate a consultant when everyone’s website says roughly the same thing. I recommend looking not at slogans but at four things:

  1. Depth of expertise in target jurisdictions
    At COREDO the team works every day with company registration and licensing in the EU, Asia and the CIS, not just occasionally.
  2. Real experience in the financial sector and AML
    If a consultant has no projects involving payment, crypto-, forex- and other licenses, it will be difficult for them to build a proper risk-based AML model. COREDO’s portfolio is built precisely around such tasks.
  3. Integration of the legal, financial and AML units
    When different consultants are responsible for registration, licensing and AML, the client often becomes a hostage to inconsistency. The COREDO team aligns everything within a single logic, from group structure to reporting to regulators.
  4. Ability to speak honestly about risks
    I always openly discuss limitations, risks and alternatives. It isn’t always pleasant in the moment, but this approach builds long-term trust.

How to use the article in practice

If you’ve read this far, you are most likely already thinking about:
  • registering a company abroad;
  • obtaining one or more financial licenses;
  • restructuring the AML‑function to align with current regulatory expectations;
  • finding a long-term partner for legal and financial support.
What I recommend doing after reading:
  • Clearly list your current and target client geographies and products.
  • Determine which of the jurisdictions and license types described in the article are relevant to you.
  • Assess how formalized your AML system is today and whether it aligns with a risk-based approach.
  • Formulate 5–7 key questions you want answers to from a consultant.
COREDO, as an international consulting company operating since 2016 and serving clients from various industries, was created specifically for such comprehensive tasks. The COREDO team has delivered dozens of projects in which registration, licensing, AML and legal support are united into a single strategy, and, in my experience, that format provides entrepreneurs with maximum resilience and freedom to grow.
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