What is AML compliance and how do you implement it

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In 2024 the volume of global fines for non-compliance with anti-money laundering (AML) laws exceeded $5.5 billion, and more than 70% of companies operating in Europe and Asia faced account freezes or refusals to register legal entities due to insufficient AML compliance. This fact is not just surprising: it prompts the question: why are even major players vulnerable to regulators? How can you avoid reputational damage and financial risks when a business expands into new markets in the EU, Singapore, Dubai or the United Kingdom?

AML compliance – is not a formality but a strategic necessity for any business seeking international expansion, obtaining financial licenses and long-term resilience. Violating requirements leads not only to fines and criminal liability, but also to loss of access to banking services, licenses and investments. The experience of the COREDO team shows that proper implementation of AML compliance becomes a key factor in successful registration of legal entities, obtaining licenses and protecting a business from sanctions.

If you want to understand how to build a robust AML program, avoid common mistakes and ensure transparency of processes in the EU, Asia and Africa: read the full article. I guarantee: you will receive practical tools and strategic ideas that will help take your business to a new level of trust and resilience.

Basics of AML Compliance: key concepts

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AML compliance (Anti-Money Laundering Compliance) – is a system of measures, procedures and policies aimed at preventing the laundering of funds obtained through criminal activity and the financing of terrorism. It is based on compliance with global AML standards, such as the recommendations of the Financial Action Task Force (FATF), as well as local regulatory requirements in the EU, Singapore, Dubai, the United Kingdom and other countries.

Key elements of AML compliance include:

  • Know Your Customer (KYC): identification and verification of customers, including legal entities and beneficial owners (Beneficial Ownership).
  • Customer Due Diligence (CDD): in-depth customer screening taking into account a risk-based approach (Risk-Based Approach).
  • Transaction Monitoring: monitoring of transactions to detect suspicious activity and preparation of Suspicious Activity Reports (SAR).
  • Sanctions Screening: client screening against sanctions lists (OFAC, EU, UN).
  • Politically Exposed Persons (PEP): identification of individuals with heightened political risk.
  • Compliance Officer / MLRO: appointment of a person responsible for compliance and reporting.
  • Anti-Terrorism Financing (ATF): integration of measures to combat terrorist financing.
COREDO’s practice confirms: implementing these principles not only protects the business but also facilitates the registration of legal entities, obtaining financial licenses and access to banking services in Europe and Asia.

Stages of implementing AML compliance in a company

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Implementing AML compliance requires a phased approach based on analysis of the business model, risks, and jurisdiction-specific characteristics. The solution developed at COREDO for international clients includes the following steps:

  1. Analysis of current processes and risks: Assessing vulnerabilities, identifying client and transaction types, analyzing compliance with global and local AML requirements.
  2. Development of the company’s AML policy: Establishing an AML policy framework structure taking into account the risk assessment methodology and KYC, CDD and EDD procedures.
  3. Appointment of a Compliance Officer / MLRO: Defining roles and responsibilities, training according to international standards.
  4. Employee training: Developing compliance training programs, conducting workshops on detecting suspicious transactions, working with sanctions lists, and internal control.
  5. Implementation of internal procedures: Creating a system of Internal Controls and Procedures, process automation for transaction monitoring and record keeping.
  6. Maintaining reporting and documentation: Establishing Record Keeping and Reporting, configuring systems for data storage and transfer, ensuring Data Privacy in AML.
  7. Conducting an independent audit: Organizing Independent Audit and Testing, preparing for regulatory inspections, adjusting policies based on audit results.
The COREDO team has implemented dozens of AML compliance projects in the EU, Singapore and Dubai, adapting processes to the requirements of each jurisdiction and the specifics of the business.

AML policy: structure and content

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An effective AML policy for a company: is not just a set of documents, but a living tool for managing risks and complying with regulators’ requirements. COREDO’s experience shows that the structure of an AML Policy Framework should include:

  • Definition of goals and objectives: Formulation of the AML program’s mission, description of key risks and strategic objectives.
  • Customer and beneficial owner identification procedures: Step-by-step instructions for Legal Entity Identification, KYC, Beneficial Ownership, CDD and EDD.
  • Risk assessment methodology: Use of Risk Assessment Methodology, definition of risk criteria, configuration of Risk Profiling.
  • Transaction monitoring and detection of suspicious operations: Description of Transaction Monitoring, procedure for preparing and filing SAR.
  • Reporting and record keeping: Record Keeping and Reporting regulations, requirements for data storage and protection.
  • Interaction with regulators: Procedure for providing information, audit preparation, response to inquiries.
COREDO’s practice confirms that a flexible and regularly updated AML policy enables rapid response to changes in legislation and regulators’ requirements in the EU, Asia, and Africa.

AML and KYC: how to integrate processes

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AML and KYC are interconnected but distinct processes. KYC (Know Your Customer) focuses on identifying and verifying the client’s identity, including legal entities and beneficial owners. AML compliance covers a broader range – from transaction monitoring to risk assessment and reporting.

В работе COREDO интеграция AML и KYC реализуется через:

  • Customer Due Diligence (CDD): basic customer checks, collection and analysis of documents.
  • Enhanced Due Diligence (EDD): in-depth checks for high-risk clients, including PEPs and complex beneficial ownership structures.
  • Legal Entity Identification: analysis of a legal entity’s structure, identification of ultimate beneficiaries.
  • Risk-Based Approach: tailoring verification procedures according to the risk level, automating processes using AML compliance Software Vendors.
COREDO places particular emphasis on the specifics of KYC when registering legal entities in the EU, Singapore, Dubai and Africa, where requirements for Beneficial Ownership and Legal Entity Identification vary by jurisdiction.

AML processes: automation and technologies

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Modern technologies are radically changing the approach to AML compliance. Automated AML solutions can reduce operating costs, increase accuracy and the scalability of an AML program.

Key technologies that COREDO implements for clients:

  • Automated AML Systems: automatic screening against sanctions lists, integration with global databases.
  • Machine Learning in AML: use of AI algorithms to analyze transactions, detect atypical patterns and prevent compliance fatigue.
  • Transaction Monitoring: real-time transaction monitoring, setting triggers for SARs.
  • Data Privacy in AML: protection of personal data and confidentiality of information during processing and storage.
COREDO’s solutions take into account the specifics of implementing technologies in companies operating in Asia and Africa, where the level of digitalization and regulatory requirements may differ significantly from the EU.

AML compliance in Europe, Asia and Africa

Regulatory requirements for AML compliance vary by country, but the FATF global standards remain the foundation for all jurisdictions. COREDO’s experience covers company registration and obtaining licenses in the EU, Singapore, Dubai, the United Kingdom, where their own regulations and procedures apply.

  • In Europe: strict requirements for beneficial ownership, mandatory Registration of legal entities, regular audits, integration with national and European sanctions lists.
  • In Asia (Singapore, Dubai): emphasis on corporate structure transparency, fast registration procedures, mandatory maintenance of registers of controllers and nominee directors, licensing of corporate service providers.
  • In Africa: the difficulty of implementing AML compliance due to insufficient digitization, limited access to global databases, and the need to adapt procedures to local conditions.
COREDO case studies show that typical AML compliance mistakes include insufficient policy detail, lack of regular procedure updates, and ignoring local requirements. COREDO’s comprehensive support helps avoid these risks and ensures compliance with requirements in any jurisdiction.

Training and AML staff audit

An effective AML program is impossible without regular staff training and independent audits. At COREDO, training is built on the principles of Compliance Training Programs, covering:

  • Fundamentals of AML compliance and KYC.
  • Working with sanctions lists and identifying PEPs.
  • Risk assessment methodology and SAR preparation.
  • Record keeping and data protection.

Independent AML audit (Independent Audit and Testing) includes:

  • Reviewing the compliance of policies and procedures with international and local requirements.
  • Analysis of the effectiveness of Transaction Monitoring and Record Keeping.
  • Preparation for regulator inspections, and adjustment of processes based on audit results.
COREDO’s experience shows: regular training and audits not only minimize risks but also increase trust from banks, investors, and regulators.

How to assess the effectiveness of an AML program

Evaluating the effectiveness of an AML program is key to resilience and return on investment (AML Compliance ROI). COREDO uses the following metrics and KPIs:
  • Number of detected suspicious transactions (SARs).
  • Speed and accuracy of customer verification (KYC, CDD, EDD).
  • Proportion of automated processes in the AML program.
  • Results of independent audits and compliance with regulatory requirements.
  • Scalability of AML Programs: the system’s ability to adapt to business growth and new markets.
The return on investment in AML is measured by reduced risks of account freezes, fines, and reputational losses, as well as by faster legal entity registration and license acquisition.

Practical steps for entrepreneurs

The COREDO team has developed a checklist for implementing AML compliance in an international company:

  • Assess risks and identify types of clients, transactions, and jurisdictions.
  • Develop an AML policy framework taking into account global and local requirements.
  • Appoint a competent Compliance Officer / MLRO.
  • Organize employee training on key aspects of AML and KYC.
  • Implement automated AML solutions for transaction monitoring and screening against sanctions lists.
  • Ensure proper record-keeping and regular reporting.
  • Prepare for an independent audit and adjust processes based on audit findings.
Avoid common mistakes: don’t copy other organizations’ policies, don’t ignore local requirements, don’t postpone employee training. COREDO’s experience confirms: a comprehensive approach to AML compliance protects the business from sanctions and fines, and ensures transparency and trust.

AML compliance as the foundation of a sustainable business

AML compliance is not only protection against risks, but also a foundation for scalable, sustainable, and competitive business. Compliance with global AML standards, integration of automated solutions, regular employee training, and independent audit are key elements that allow companies to operate successfully in Europe, Asia, and Africa.

COREDO’s experience has shown: the proper implementation of AML compliance speeds up the registration of legal entities, facilitates obtaining financial licenses, protects against reputational losses, and opens access to international markets. In the context of tightening regulatory requirements and growing compliance fatigue, a strategic approach to AML becomes a competitive advantage for any business.

Key stages in implementing AML compliance

Stage Description Key actions
risk analysis Assessment of current processes and risks Conducting risk assessment, identification of vulnerabilities
Policy development Creating the company’s AML policy Defining objectives, procedures, responsible parties
Appointment of a responsible person Selection of an AML Officer/MLRO Defining roles and responsibilities
Employee training Conducting AML training Program development, conducting training sessions
Implementation of controls Implementation of internal procedures Development and implementation of internal control procedures
Maintaining documentation Maintaining reporting and documentation Establishing a reporting system and document storage
Audit Conducting an independent audit Audit preparation, compliance check
Key takeaways:
  • AML compliance is a mandatory requirement for legally conducting business abroad.
  • Implementing AML compliance requires a comprehensive approach: from policy development to employee training and process automation.
  • Technology and automation help reduce risks and increase the effectiveness of the AML program.
  • Particular attention should be paid to requirements in different jurisdictions and to regularly updating the AML policy.
  • AML compliance is not only protection against risks but also a competitive advantage for the business.
If you are looking for a reliable partner for implementing AML compliance, registering legal entities and obtaining financial licenses in Europe, Asia and Africa: the COREDO team is ready to offer strategic solutions tailored to your business and the specifics of the jurisdiction.
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