The three lines of defence
Accountability at
every level of the organisation
We define who decides, who checks and who escalates, across all three lines. No gaps in oversight, no doubt about accountability.
Business lines
Own & manage risk
- Customer acceptance decisions
- KYC/CDD execution
- Transaction monitoring alerts
- First-level escalation
Compliance function
Oversee & advise
- Policy ownership
- MLRO mandate
- Regulatory reporting
- Training & awareness
Internal audit
Independently assure
- Programme effectiveness review
- Control testing
- Findings & recommendations
- Board reporting
Five governance services
From board mandate
to independent assurance.
01
AML/CFT governance & control framework
Design of comprehensive AML/CFT governance frameworks — defining board and senior management responsibilities, compliance committee structures, escalation protocols, and the three-lines-of-defence model. We ensure governance arrangements meet FATF Recommendation 18 and applicable supervisory expectations.
02
Policies & procedures
Development of the full AML/CFT policy and procedure suite — from the overarching AML/CFT policy to granular operational procedures covering KYC, transaction monitoring, sanctions, STR, and record-keeping. All documentation is calibrated to your risk profile and regulatory environment.
03
AML/CFT Operating Model & Compliance Function Design
Design of the AML/CFT operating model — defining the compliance function's mandate, organisational structure, reporting lines, resource requirements, and interaction with business lines. We design MLRO roles, deputy structures, and compliance committee charters aligned to regulatory expectations.
04
Independent audit & compliance testing
We test both the design and the real effectiveness of your controls, as a third line would. You get actionable findings and credible evidence for the regulator.
05
Regulatory Inspection Readiness & Remediation
Pre-inspection diagnostic and remediation support — simulating supervisory examination methodologies, identifying governance and documentation vulnerabilities, and preparing your compliance function, board, and senior management for regulatory scrutiny. Post-inspection remediation planning and implementation support also available.
Is your governance
ready to be audited?
Talk to an AFINUR specialist about your compliance function and your independent assurance needs.
Confidential: all our engagements are covered by professional secrecy.
The board at the centre
We give the board and management the committees, reporting lines and escalation rules they need to meet their AML/CFT responsibilities.
A strong MLRO mandate
Authority, resources, independence and direct access to the board: a mandate that meets regulators' expectations.
Independent assurance reviews
Conducted independently of the compliance function, our reviews give the board and audit committee an objective view of programme effectiveness.
Further reading