AML audit in Latvia typical findings

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As CEO and founder of COREDO, I see daily how entrepreneurs from Europe, Asia and the CIS face the challenges of international expansion: from registering companies in new jurisdictions to obtaining financial licenses and ensuring strict AML compliance. Our experience at COREDO since 2016 covers hundreds of projects in the EU, Czechia, Slovakia, Cyprus, Estonia, the United Kingdom, Singapore and Dubai, where the COREDO team consistently turns regulatory barriers into competitive advantages. In this article I will cover the key aspects — from corporate registrations to AML audits in Latvia and minimizing risks under the 6AMLD in Latvia, with practical steps based on real cases.

Important to note right away:

Latvia – not a “typical” EU jurisdiction from an AML perspective. After the banking crises and increased supervision, Latvijas Banka has formed one of the most conservative AML practices in the region. This means increased scrutiny of cross-border operations, sources of funds from the CIS and Asia, as well as structures with crypto and forex exposure.

That’s why

companies that pass onboarding without issues in other EU countries often encounter AML audit findings in Latvia at an early stage. Later in the article I will explain how to prepare for this systematically rather than reactively.

Registering companies abroad: choosing a jurisdiction

Illustration for the section «Registration of companies abroad: choosing a jurisdiction» in the article «AML audit in Latvia — typical findings»

A common mistake is to treat AML as a step after company registration. In Latvia the logic is the opposite: the business risk profile is formed before the legal entity is opened, based on the founders, the geography of capital and the intended business model. Latvijas Banka and partner banks analyse this data in advance, and it is extremely difficult to change the first impression afterwards.

company registration in the EU or Asia in 2025 requires a focus on digital identification and KYC — audits and Latvia-like procedures. In the EU, including Latvia and Estonia, video verification of founders via eIDAS or BankID is mandatory, plus confirmation of the source of funds (source of funds verification). The COREDO team implemented this for a fintech startup from Singapore that opened an SPV in Cyprus: we integrated electronic signatures, reducing timelines from 5 weeks to 10 days. In Asia, in Singapore and Dubai, we similarly strengthened KYC automation, with checks of beneficial owners against sanctions lists.

According to COREDO’s practice, key red flags when registering and opening accounts in Latvia:

  • sources of funds not documented for the past 2–3 years;
  • UBO with a business history in high-risk jurisdictions without EDD;
  • use of nominee directors without real decision-making;
  • mismatch between the declared business model and actual transaction flows;
  • absence of a pre-prepared AML framework.
Formal KYC does not close these risks — they surface during the first AML audit.

COREDO’s practice confirms: for high-risk business (crypto, forex) choose jurisdictions with remote registration. In Latvia under the supervision of Latvijas Banka the process takes 2–4 weeks, but requires a business plan and AML compliance from the very start. Steps we recommend:

  • Assess a risk-based approach: the EU focuses on predicate offences under 6AMLD (including Latvia), while Asia focuses on cross-border transaction risks.
  • Gather the package: articles of association, registered address, eKYC questionnaires, proof of business reputation.
  • Integrate ESG and automated reporting for bank accounts — EU banks now require this for high-risk clients.

Practical checklist for AML registration in Latvia:

  • ownership structure without ‘extra layers’;
  • confirmed source of funds and source of wealth;
  • description of business processes and client types;
  • preliminary AML risk matrix;
  • understanding of SAR reporting obligations;
  • designated AML officer in place from the start.
This approach allows passing the initial bank filter without additional rounds of questions.

For companies from Asia scaling into the EU, the solution developed by COREDO combines registration in Estonia with a holding structure in Dubai: full disclosure of beneficiaries minimized delays in account opening.

Financial licenses: MiCA and payment services

Illustration for the section «Financial licenses: MiCA and payment services» in the article «AML audit in Latvia — typical findings»
obtaining licenses – crypto (MiCA), banking, forex or payment – directly depends on AMLR requirements and internal procedures. In Latvia and the Czech Republic, for MiCA licenses Latvijas Banka checks transaction monitoring systems and AML stress testing. Our experience has shown: typical refusals arise from KYC gaps in Latvia, such as incomplete identification of beneficiaries or weak PEP monitoring.

For EU regulators a license is not permission “to start a business”, but confirmation of the company’s ability to manage financial and AML risks over time. In Latvia this approach is particularly strict: a licensed company is considered a potential systemic risk if its AML frameworks are not ready to scale.

The COREDO team accompanied a client from the United Kingdom to a payment license in Slovakia: we implemented a graph-based transaction analysis with explainable AI AML, identifying unusual patterns and securing approval in 8 weeks.

Notably:

In Latvia and the EU more broadly regulators view “black boxes” in AML negatively. The model must be explainable — why the system assigned a risk, why an alert was generated, who made the final decision.

This is why COREDO implements explainable AI: it not only reduces false positives but also helps protect the company’s position during regulatory inspections.

Key steps:

  • Conduct a gap analysis against 6AMLD requirements (Latvia): focus on enhanced Due Diligence (EDD) for PEPs and source of wealth checks.
  • Develop a compliance officer structure with a clear point of accountability for AML.
  • Integrate AI-driven anomaly detection for transaction monitoring in Latvia — this reduces operational costs by 30–40% and increases ROI.
In Singapore, for a forex license add vendor risk AML checks; in Dubai: a Free Zone with zero tax but strict SAR reporting similar to Latvia. COREDO’s work with Asian traders confirms: linking AML documentation with MiCA internal controls reduces reputational risks.

AML consulting in Latvia and the EU

Illustration for the section «AML consulting in Latvia and the EU» in the article «AML audit in Latvia - typical findings»

AML audit in Latvia is not a formal document check. Auditors and the regulator assess three levels:

  • Design – correctness of the AML architecture;
  • Implementation – actual application of procedures;
  • Effectiveness – whether controls work in practice.
Most negative findings arise at the effectiveness level, not the policy level.

AML audit Latvia is a priority for business in the EU, especially with the new AMLR compliance in Latvia and the risks of AMLA sanctions in Latvia. Typical AML findings include logical gaps in schemes, delays in SAR reporting and ineffective transaction monitoring. In 2025 fines for AML violations in the EU reach 10% of turnover or €10 mln under AML fines 10% of turnover.

Our experience at COREDO identified typical AML audit violations in Latvia for fintech: weak post-transaction analysis (predicate offences as organised crime ML threats) and gaps in KYC. For a client from the CIS we conducted AML checks in Latvia, implementing stress-testing of AML procedures in Latvia and eIDAS KYC – this eliminated findings and passed the regulatory audit of Latvijas Banka.

Typical AML audit findings in Latvia for fintech:

Finding Description COREDO solution
PEP screening weaknesses Lack of automated tools for PEP monitoring in Latvia PEP screening tools with graph neural networks
Transaction monitoring findings Unusual cross-border patterns Automated AML monitoring with explainable AI
KYC gaps in Latvia Incomplete source of funds checks Automation of onboarding and EDD
SAR reporting delays Inefficiency of internal escalation procedures Financial crime dashboard for Latvia to improve responsiveness
6AMLD violations in Latvia Ignoring predicate offences AML risk assessment matrix with training programs

How to identify AML gaps yourself before a regulatory audit:

  • test 10-15 high-risk client cases “from end to start”;
  • check the speed and quality of SAR escalation;
  • compare risk scoring with actual transactions;
  • review decision logs of the AML officer;
  • assess which monitoring scenarios generate noise.
This mini-audit often reveals problems faster than a formal inspection.

The COREDO team integrated transaction scoring and sanctions filters, minimizing the risk of AMLA sanctions for companies in Latvia. How to identify gaps in AML compliance in Latvia? Start with internal control: assess financial crime risks in Latvia, including financial ties risks in Latvia. Practice confirms: explainable AI for AML analysis in the EU detects 20–30% more anomalies than manual methods, especially for CIS businesses with PEPs in transactions.

6AMLD in Latvia has strengthened personal liability of directors and compliance officers. This means that “we didn’t know” is no longer an argument.

Companies are required to prove that risks of predicate offences were identified and controlled. Explainable AI plays a key role here – it forms the evidential basis of decisions.

Support: from audit to scaling

Illustration for the section «Support: from audit to scaling» in the article «AML audit in Latvia - typical findings»

In Latvia projects COREDO works systemically rather than ad hoc: from structure diagnostics to building a resilient AML architecture. We consider AML as part of the business model, not an isolated compliance function.

COREDO provides a full cycle: after registration we implement compliance training programs, automate transaction monitoring AML and prepare for inspections. For a crypto company from Dubai expanding into the Czech Republic, we linked MiCA AML license with internal AML control, preventing AML-related reputational losses.

The ROI from an AML audit in Latvia is high: clients save 50% of time, avoid fines for non-compliance with 6AMLD in Latvia and scale into the EU. Scaling AML compliance in the EU for Asian companies requires stress-testing of compliance and reporting obligations under AMLR; COREDO adapts to the new AMLR reporting obligations.

In our Latvia projects, investments in AML optimization pay off within 6-9 months:

  • reducing operational compliance costs by up to 40%;
  • accelerating onboarding and licensing by 30–50%;
  • reducing the risk of fines and account blocks to almost zero.
For international groups, this becomes a competitive advantage when entering the EU market.

Ultimately, a reliable partner solves pains with transparency: the COREDO team is always available, from due diligence to ongoing support. If you are planning expansion, start with an audit; it’s an investment in sustainable growth. Contact us and we will review your case individually.

The conclusion is simple:

in Latvia formal AML is not just ineffective – it is dangerous. Only risk-oriented, explainable and business-integrated AML allows scaling without sanctions, account blocks and reputational losses.

COREDO helps build exactly such a system — from registration to ongoing compliance and regulatory inspections.

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