AML audit when changing the beneficial owner what banks check

Nikita Veremeev

11.01.2026 | 6 min read

Updated: 11.01.2026

When in 2016 I launched COREDO, I had a very simple idea: international business should receive clear and predictable solutions, not a collection of disparate services from a dozen consultants in different countries. Since then the COREDO team has grown from a small consultancy to a partner that takes on the full cycle of tasks: from company registration in the EU, Asia and the CIS to obtaining financial licenses, setting up AML frameworks and long-term business support.

In this article I want to candidly and to the point examine three key questions that you, as an owner or chief financial officer, face in international projects:

• how to choose and structure jurisdictions for a company;
• how to approach licensing (banking, payment, crypto, forex and other licenses);
• how to build a sustainable AML system and a comprehensive support model so that the business runs smoothly, not from one inspection to the next.

And at the same time I’ll show how we solve these tasks in practice at COREDO: with numbers, case studies and concrete approaches.

Choosing a jurisdiction for business

Over the years I have become convinced: the mistake is not a “bad” country, but a misformulated objective. The same jurisdiction can be perfect for a fintech startup and completely unsuitable for a traditional trading business.

When a client comes to me with the request “just need a company in the EU”, I always slow the process down and ask five basic questions:

1. Where are the key clients and suppliers located?
   This affects VAT, permanent establishments and the risk of tax claims in the countries of presence.
2. Do you need access to licensing (financial services, crypto, payments)?
   Some countries offer more flexible regimes for fintech, others are more conservative but respected by regulators and partner banks.
3. What target level of substance (office, employees, directors) are you prepared to maintain?
   In the EU, requirements for economic presence are gradually tightening, and this must be honestly taken into account when planning the structure.
4. What constraints do you have on timelines and budget?
   Some jurisdictions register in a few days, others take months, especially when a financial license is involved.
5. What is the exit strategy: attracting an investor, selling a stake, IPO?
   For investors from the US, Europe or Asia, the choice of jurisdiction is often as important as the product.

COREDO registration process

At COREDO this has long been formalized as a “registration roadmap”. For the client, the process looks as transparent as possible:

1. Pre-project analysis
   • beneficiary checks (KYC, sources of income);
   • analysis of the business model for compliance with requirements of the local regulator;
   • preliminary structuring (holding, operating company, licensable entity).
2. Choosing the jurisdiction and company form
   • In the EU and United Kingdom this could be, for example, a private limited / s.r.o. / OÜ;
   • In Singapore and Dubai: local legal forms, which we structure according to the client’s objectives.
3. Preparation of corporate documents
   At COREDO we handle the articles of association, shareholders’ resolutions, corporate agreements, option programs if the business is investment-oriented.
4. KYC processing at banks and financial institutions
   This is where COREDO’s AML team experience comes into play: we pre-model the bank’s questions, prepare justification of sources of funds, the business plan, and financial forecasts.
5. Launch of operational activities and basic compliance setup
   • basic policies and procedures;
   • contractual framework (contracts, offers, privacy policies, AML disclaimers).

Case: European holding and Asian fintech

A few years ago an entrepreneur approached us who was already running an IT business in Asia and wanted to launch a licensed fintech product targeted at clients from the EU and Asia.

The solution developed at COREDO included:

• a holding company in one of the EU countries with a well-developed treaty framework for avoiding double taxation;
• an operational licensed structure in an EU country where a modern regulatory framework for payment institutions is available;
• a service center in an Asian jurisdiction with a strong technological ecosystem.

The COREDO team ensured the registration of all legal entities, the preparation of documents for banks, the structuring of agreements between companies, and the launch of AML procedures at the start. The client received a working structure within reasonable timeframes, without ‘paralysis’ caused by working with multiple consultants simultaneously.

Financial licenses: how to get approval

The strategically right license is not only access to the market, but also a level of trust from partners. At COREDO we systematically work with licenses in the EU, the United Kingdom, Switzerland, and certain countries in Asia and the CIS.

Typical requests include:

• licenses for payment institutions and electronic money;
• Banking licenses (including for niche players);
• licenses for investment services and forex;
• cryptocurrency licenses and registration of virtual asset service providers;
• Licensing of specialized financial institutions.

Why licensing is not just paperwork

My experience has shown: the likelihood of license approval drops significantly when the applicant treats the process as a “technical submission of documents”. The regulator looks not only at completeness, but also at:

• maturity of the business model;
• strength of the compliance culture;
• transparency of beneficial owners and sources of funds;
• quality of risk management and AML approaches.

Therefore, at COREDO we structure the work as a project cycle:

1. License readiness assessment
   The COREDO team analyzes the client’s current state: corporate structure, processes, presence or absence of AML policies, and the level of documentation.
2. Choice of jurisdiction and type of license
   Sometimes it makes sense to start with a registration regime or a limited license, and then scale. Our experience at COREDO has shown that a staged approach is often more effective than trying to “get the maximum” immediately.
3. Development of internal documents
   • risk management policies;
   • AML/CTF policies;
   • KYC procedures/KYB;
   • transaction monitoring methodologies;
   • governance documents (board of directors, committees, responsibilities of key persons).
4. Application submission and interaction with the regulator
   At this stage the COREDO team supports communication, prepares responses to inquiries, and adjusts documents in accordance with the regulator’s comments.
5. Post-licensing support
   The regulator expects reporting, internal audits, and policy updates. COREDO often remains a long-term partner, providing legal, compliance, and AML support.

License for a crypto provider

One of the illustrative cases is obtaining a license for a crypto company that serves clients from the EU and Asia.

The client approached requesting “a crypto license in one of the EU countries.” In our preliminary analysis we saw:

• a strong technological product;
• a poorly formalized AML component;
• lack of a clearly defined governance structure and role distribution.

The solution developed at COREDO included:

• choosing a jurisdiction with a clear regulatory practice for crypto services;
• establishing a legal entity and preparing a full package of corporate documents;
• development of AML policies, identification and monitoring procedures, and a client risk matrix;
• preparation of a business plan and financial forecasts in the format expected by the local regulator;
• support at all stages of dialogue with the regulator.

AML consulting: how to avoid risks to a license

AML has long stopped being only about banks. COREDO’s practice confirms that regulators and financial partners pay equal attention to payment companies, crypto projects, investment platforms and even some trading businesses.

What AML work entails

When we at COREDO say «AML consulting», we are not talking about a boilerplate 40-page policy that sits on a server “for show”. A real AML framework includes:

• risk assessment by countries, client segments, product types;
• development and implementation of KYC/KYB processes, including enhanced Due Diligence;
• methodologies for monitoring operations and detecting suspicious transactions;
• protocols for interacting with financial institutions and regulators;
• employee training and assignment of responsibility.

COREDO often gets involved in two typical situations:

• the business is being launched and AML processes need to be built in from scratch;
• the business is already operating but has run into problems: requests from banks, account freezes, regulatory remarks.

Common mistakes made by international companies

Experience has shown several common mistakes:

1. Copying someone else’s policies
   The document does not reflect the real business model, and the regulator quickly sees this from transactions and the client base.
2. Gap between legal documents and IT systems
   On paper the process is ideal, but in reality the system does not collect the necessary data and does not record decisions on risk cases.
3. Underestimating partner banks’ requirements
   A bank is often more conservative than the regulator. It is important to consider not only the law but also the internal policy of a particular financial institution.
4. Lack of regular review
   The AML policy was created at project launch and was not updated afterwards, despite changes in products, geography and transaction volumes.

The COREDO team builds AML projects to avoid these mistakes: it all starts with an honest description of the real business, not an idealized picture.

COREDO’s comprehensive client support

Many come to us for company registration or a license, and stay for years thanks to comprehensive support. This is a deliberate model: I originally built COREDO as a full-cycle partner, not a “one-off agency”.

• legal services and protection in the necessary jurisdictions (contracts, corporate law, dispute resolution with financial institutions);
• registration and protection of trademarks in EU countries, the UK and other regions;
• AML and regulatory compliance (policies, training, internal audits);
• accounting outsourcing and reporting tailored to the requirements of the specific country of registration;
• support for opening bank accounts and working with payment providers.

Fintech: multi-jurisdictional reporting

One of our clients is a fintech project with a licensed structure in the EU, operational teams in Asia and clients from various regions.

The COREDO team implemented the following for the client:

• registration of several companies in the EU and Asia;
• obtaining a financial license;
• implementation of AML policies and procedures;
• ongoing legal support (contracts with partners, user agreements, privacy policies);
• support in registering trademarks in key markets;
• coordination of accounting and tax reporting across different jurisdictions.

Thanks to a single team of consultants, the client does not waste resources synchronizing between lawyers, accountants and AML specialists in different countries. For me, this is the key measure of quality: when a business can focus on the product and growth, rather than “putting out” legal and regulatory issues.

How to choose a consultant

1. Focus and specialization
   It’s important that the consultant works systematically with international registration, financial licenses and AML, rather than treating it as “one of the services”.
2. Experience in relevant jurisdictions
   Company registration in the Czech Republic is very different from licensing in Singapore or structuring in Dubai. Practice is needed, not just theoretical knowledge.
3. Transparency of processes and communications
   You should understand what stage the project is at, what the risks are and the timelines. Here honesty is more important than optimistic promises.
4. Having a team, not a single “jack-of-all-trades”
   Registration, licensing, AML and legal support are different competencies. At COREDO, specialists of different profiles work on projects, and that is what provides depth.
5. Willingness to talk about difficulties
   If a consultant promises “quickly, without problems and questions from the regulator”, I would be cautious. A proper dialogue with the regulator always includes clarifications, revisions and hands-on work with documents.

In one recent inquiry a client put their expectations this way: “We need a partner who not only knows the AML procedure, but also understands how regulators and banks interpret it in practice.”

This request resonates well with my own position. Yes, COREDO actively uses industry knowledge, international standards and Russian and European approaches to AML, but it always keeps the boundaries of its competencies in mind.

If you are planning to enter a new region, are considering a license, or realize that AML and compliance processes in your company need to be reviewed, it is important to ask the right questions in time and build a system rather than patch individual problems. This is exactly the format in which I am used to working with COREDO clients and exactly how I see the role of a reliable long-term partner in international consulting.