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An AML implementation that works in day-to-day operations

We design and implement an AML process tailored to the scale and operating model of your organisation. This makes clear what applies to you, who is responsible for what, and how to apply the rules in practice-without disorder or disruption to the business.

Let’s discuss AML implementation

Awareness of AML obligations alone does not bring order to an organisation. The problem begins when the rules exist, but no one knows how to translate them into day-to-day decisions, responsibilities, and the team approach to working.

“The greatest risk is not the absence of a document. The greatest risk is a system that formally exists but does not work in practice.”

In many companies AML is implemented ad hoc: there are isolated procedures, outdated templates, or intuitive team actions. That does not give management control or employees clear rules. The result is always similar: uncertainty, discretionary decisions, overload of the people responsible, and the risk that gaps will surface at the worst possible moment.

Agnieszka Sowula-Nowakowska

Senior Associate

Common problems and challenges

The most common problems we solve

We know AML applies to us, but we do not know where to start The organisation is aware of its obligations but is not certain what scope of AML genuinely applies to it or what needs to be implemented first.

We begin by organising the obligations and mapping the gaps. This gives the client a clear starting point, a sequence of actions, and an implementation scope tailored to its situation. Without this, the matter is usually postponed further and the risk continues to grow.

The documentation exists, but it does not create a process The company has procedures, templates, or older documents, but no one is certain that they are current, consistent, and useful in practice.

We organise or design the documentation so that it supports the actual operating process. The business benefit is not another binder, but tools that can be used every day. Without this, AML remains on paper and provides no operational security.

It's unclear who is responsible for what A lack of a clear division of roles overloads a single person, causes delays, and creates chaos in decision-making.

We design roles, responsibilities, escalation paths and information flows. This enables the organisation to understand who performs each obligation, who makes decisions and when a matter requires escalation. Without this framework, accountability becomes blurred and the management board assumes more risk than it should.

The team acts intuitively instead of following rules Similar situations are handled differently because employees lack a shared model for assessing risk, identifying clients and documenting actions.

We translate AML into operational practice: concrete operating rules, forms, instructions, and decision points. The result is greater predictability and less discretion in the team’s work. Without this, every more difficult situation returns as an ad hoc problem.

Similar situations are resolved differently because employees lack a common model for risk assessment, customer identification, and documenting actions. Managers feel responsible for the AML area but lack a clear model for oversight and control of what is actually happening in the organisation.

We build a system that organises responsibilities, decisions, and documentation. This gives management greater control over risk and better insight into how the organisation operates. Without such a model, liability remains high and control is merely apparent.

The company fears an excess of procedures The client does not want an implementation that looks correct on paper but burdens the team and hinders the business in practice.

Managers feel responsible for the AML area but lack a clear model for oversight and control of what is actually happening in the organisation.

Our solution

We design AML systems so that organizations know what to do and how to implement them.

This service goes beyond simply identifying responsibilities. Its goal is to build a cohesive AML model that fits the organization, clarifies responsibilities, and provides tools for day-to-day operations.

We design AML systems so that organizations know what to do and how to implement them.

This service goes beyond simply identifying responsibilities. Its goal is to build a cohesive AML model that fits the organization, clarifies responsibilities, and provides tools for day-to-day operations.

Identification of AML obligations

  • analysis of the organization’s operating model
  • determining which AML obligations actually apply to the company
  • defining the scope of implementation required

An AML obligations map and a clear starting point for further action.

Internal model design

  • defining roles and responsibilities
  • streamlining decision-making and escalation paths
  • designing information flows and documentation processes

A coherent AML operating model tailored to the organization’s structure.

Risk assessment and customer service policies

  • streamlining customer identification procedures
  • defining the approach to risk assessment
  • establishing rules for monitoring relationships and documenting activities

Practical guidelines for handling typical and more challenging operational situations.

Preparation of AML documentation

  • AML procedures
  • risk assessments, forms, templates, and instructions
  • materials needed to implement the new model

A complete set of documents ready for use, not for archiving.

Tailoring the solution to the organization

  • taking the company’s size and industry into account
  • adapting the solution to the team’s way of working
  • limiting unnecessary procedural complexity

An AML system proportionate to the organization’s obligations and practical for everyday use.

Who is this service for?

Who is this implementation for?

This service is for organizations that want to streamline AML in a practical, proportionate, and commercially sensible way.

Who is this implementation for?

This service is for organizations that want to streamline AML in a practical, proportionate, and commercially sensible way.

Head of Operations

when AML needs to be translated into clear team working rules and chaos in day-to-day decisions reduced.

Compliance Officer / Compliance Specialist

when a coherent model of responsibilities, documentation, and operational processes is needed-not a collection of disconnected formalities.

Stages of work

How the collaboration works

We work in stages so that the client knows from the outset what we are doing, why we are doing it, and what outcome each step is intended to deliver.

Diagnosis and mapping of obligations

We analyse the organisation’s situation, operating model, risks and the scope of its AML obligations.

AML system design

We build the target operating model: roles, responsibilities, processes, decision-making paths and documentation methods.

Documentation and implementation plan

We prepare procedures, forms, templates, instructions and a plan for launching the system.

Launch and stabilisation of the practice

We support the initial application of the new rules, clarify uncertainties and organise operations after launch.

Let’s discuss AML implementation

Let’s discuss AML implementation

Write to us

Put your AML in order before chaos becomes a real risk

One conversation is enough to assess what scope of implementation makes sense for your organisation and where best to start.

Briefly describe your situation, industry and current stage. We will come back to you with a proposed next step and an initial approach.

Agnieszka Sowula-Nowakowska

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