AML/CFT Framework Development

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Your AML/CFT framework is the foundation of your compliance programme. It is what the regulator assesses, what your auditors review, and what your staff rely on every day. A framework that was copied from a template or built for a different business model creates risk - not protection.

Kybri builds AML/CFT frameworks from the ground up, tailored to how your business actually operates. Whether you are starting from scratch, overhauling an inherited framework, or adapting to new regulatory requirements, we deliver frameworks that are practical, proportionate, and regulator-ready.

What we deliver:

• Business-wide risk assessment (BWRA) aligned with your specific activities, customers, products, and jurisdictions
• AML/CFT policies and procedures covering CDD, EDD, ongoing monitoring, PEP management, sanctions screening, and suspicious activity reporting
• Customer risk scoring methodology and risk appetite framework
• Transaction monitoring rules and escalation procedures
• Governance structures, roles, and responsibilities
• Record-keeping and data retention policies
• Board and management reporting templates
• Staff training materials and training delivery as part of the framework rollout

Every framework is designed to meet the regulatory expectations of your jurisdiction - whether that is the Isle of Man AML/CFT Code 2019, the UK MLRs, MiCA, or another regime - while remaining practical and operationally workable.

We do not deliver generic templates. We deliver working frameworks that reflect your business.

Engagement model: Project-based or ongoing retainer for framework maintenance and updates.