AFINUR
Advisory›Financial crime compliance

On inspection day,
your controls speak for themselves.

KYC, sanctions, transaction monitoring and suspicious reporting: AFINUR designs complete AML/CFT programmes, fitted to your institution's risk profile and ready for inspection.

Five core controls

Five controls.
No blind spots.

01

Customer due diligence & KYC

Client identification and verification, beneficial ownership, enhanced due diligence, PEPs and ongoing monitoring: we build risk-based KYC in line with FATF Recommendations 10, 12 and 22 and your national rules.

Deliverables

  • KYC/CDD policy and procedures
  • Customer risk rating methodology
  • Beneficial ownership framework
  • EDD for high-risk clients

02

Sanctions screening

Screening policy, list management (OFAC, EU, UN, OFSI), matching rules, alert handling and escalation: we design your programme, then tune it to cut false positives without missing true matches.

Deliverables

  • Sanctions policy
  • Screening calibration review
  • Alert handling procedure
  • Escalation and false-positive clearance procedures

03

Transaction monitoring

Scenario selection, thresholds, alert triage, case management and model validation: fewer useless alerts, and genuine suspicion escalated in time.

Deliverables

  • Scenario library and calibration
  • Alert triage procedures
  • Case management framework
  • Model validation report

04

Suspicious transaction reporting

Suspicion criteria, internal escalation, FIU reporting format and staff training: your reports are filed on time and well documented, and the institution is protected against tipping-off risk.

Deliverables

  • STR policy and procedures
  • Suspicion indicators
  • FIU reporting templates
  • Staff training programme

05

Correspondent banking due diligence

Correspondent assessment, Wolfsberg questionnaires, ongoing monitoring and de-risking decisions: a programme aligned with FATF Recommendation 13 and the Wolfsberg Principles.

Deliverables

  • Correspondent banking policy and procedures
  • Correspondent assessment framework
  • Wolfsberg questionnaire templates
  • De-risking decision framework

Our approach

One joined-up programme,
from risk to evidence.

Your controls work as one system, not a stack of separate policies. Each one flows from your risk assessment and is documented for inspection.

THE COMPLIANCE CYCLE

01

Risk assessment

Every control starts from your risk profile

02

Policies

Policies that meet your rules

03

Controls

Applied in every business line

04

Testing

Effectiveness independently verified

05

Ongoing monitoring

Settings reviewed continuously

Ready to show
your controls to the regulator?

Talk to an AFINUR specialist about your AML/CFT programme and which controls to strengthen first.

Confidential: all our engagements are covered by professional secrecy.

Compliance professional reviewing AML/CFT documentation

Our Commitment

"Effective AML/CFT compliance is not a policy document — it is a living system of controls, culture, and accountability."

— AFINUR Financial Crime Practice

Compliance professional reviewing AML/CFT programme documentation
Effective financial crime compliance is not a policy document — it is a living system of controls, culture, and accountability that must be tested against the reality of how your institution actually operates.

AFINUR Financial Crime Practice

From policy to day-to-day control

We build the AML/CFT programme from policies down to daily controls, consistent at every level.

Inspection-ready

Every deliverable is built to be shown to the regulator, FATF assessors and internal audit.

Every sanctions regime

EU, OFAC, UN and UK, including multi-jurisdiction exposure and correspondent banking risk.

Suspicious reporting

A reporting process that meets the legal duty without overloading your teams.