Specialised Solutions for E-Money Institutions’ Compliance Management

We offer a comprehensive set of risk and compliance solutions tailored to a variety of e-money institutions' compliance obligations. We can help you comply with e-money institutions' regulations in a commercially oriented and goal-focused manner, providing a tailored approach to EMI compliance management with regard to your specific circumstances, including:

• Your commercial objectives
• E-money products you offer
• Your business size
• Your technology and human resources
• Your risk appetite
• Your governance structure
• Your client demographics
• Your countries of operation, their applicable laws, and relevant e-money institutions' licensing requirements and regulations, including key aspects such as outsourced providers' monitoring, compliance training, risk management, audit, and assurance.
• Any related compliance obligations, including, but not limited to, e-money institutions' obligations under privacy laws, anti-money laundering and counter-terrorist financing (AML/CFT) laws, fair trading laws, and more.
• E-money institutions' compliance assurance obligations, including internal control design and testing, implementation of compliance calendars, management plans, compliance assurance programs and other second and third-line compliance requirements.
• Specific operational compliance requirements for e-money institutions, including but not limited to:
  • Client due diligence and onboarding
  • Surveillance and monitoring
  • Recordkeeping
  • Conflict of interest management
  • Regulatory technology (RegTech) integration
  • Internal reporting
  • External reporting
  • Transaction execution
  • Regulatory Filings

 

 

What Jurisdictions Do Our Compliance Solutions Cover?

Our compliance solutions extend across major financial markets and cover e-money institutions' regulation and e-money institutions' licensing requirements in the following jurisdictions:

• Australia: Where e-money institutions are typically regulated by the Australian Securities and Investments Commission (ASIC) under the Corporations Act 2001. Typically, these institutions require an Australian Financial Services Licence (AFSL).
• United States: Where e-money institutions are regulated at both the federal and state levels. Federal regulation includes compliance with the Electronic Fund Transfer Act (EFTA) and state-specific Money Transmitter Licenses.
• United Kingdom: Where e-money institutions are regulated by the Financial Conduct Authority (FCA) under the Electronic Money Regulations 2011.
• Singapore: Where e-money institutions are regulated by the Monetary Authority of Singapore (MAS) under the Payment Services Act.
• European Union: Where e-money institutions should comply with the E-Money Directive (EMD) and the Payment Services Directive (PSD2), regulated by national competent authorities.
• Cayman Islands: Where e-money institutions fall under the broader financial services regulations and may require licensing from the Cayman Islands Monetary Authority (CIMA) under the Money Services Law.
• Bermuda: Where e-money institutions are regulated by the Bermuda Monetary Authority (BMA) under the Digital Asset Business Act 2018.
• Gibraltar: Where e-money institutions are regulated by the Gibraltar Financial Services Commission (GFSC) under the Financial Services (Electronic Money) Regulations 2011.
• British Virgin Islands: Where e-money institutions are regulated by the British Virgin Islands Financial Services Commission (BVI FSC) under the Financing and Money Services Act.
• Seychelles: Where e-money institutions are regulated by the Financial Services Authority (FSA) under the Financial Services Authority Act.
• Vanuatu: Where e-money institutions are regulated by the Vanuatu Financial Services Commission (VFSC) under the Financial Dealers Licensing Act.

 

 

What Types of E-Money Institutions Do We Support? 

Our compliance solutions for e-money institutions cover the following types of financial entities:

• Electronic Money Issuers (EMIs): Institutions issuing electronic money for use in payment transactions, including prepaid cards and online accounts.
• Payment Institutions (PIs): Entities providing payment services such as money remittance, payment transactions, and issuing payment instruments.
• Mobile Money Operators: Companies offering financial services through mobile phone platforms, including mobile wallets and payment services.
• Stored Value Facilities Providers: Businesses providing facilities where users can store monetary value electronically for future payments or transfers.
• Prepaid Card Issuers: Companies issuing prepaid cards that can be used for purchases or cash withdrawals.
• Cryptocurrency Wallet Providers: Platforms for the storage of cryptocurrencies, which may be subject to e-money regulations in certain jurisdictions.
• Remittance Service Providers: Companies offering cross-border money transfer services, which may fall under e-money or payment services regulations.
• FinTech Companies Offering E-Money Services: Innovative financial technology firms providing e-money solutions, including peer-to-peer payments and digital wallets.
• Virtual Asset Service Providers (VASPs): Entities dealing with digital assets that may be regulated under e-money frameworks depending on the jurisdiction.
• Payment Gateways and Processors: Businesses facilitating electronic payment transactions between merchants and customers.

 

E-Money Institutions’ Compliance Advisory

Our focus areas include:

• Detailed Compliance Advice: Covering EMI compliance management issues across the first, second, and third lines, as well as matters related to effective compliance with financial markets regulations and e-money institutions' licensing requirements.
• Banking Relationships Advice: On risk and compliance issues related to managing and expanding relationships with banks, liquidity providers, and other financial institutions to help you meet their risk appetite requirements, anti-money laundering and counter-terrorist financing requirements, fraud prevention and recall volume expectations, and other compliance-related and operational standards.
• Operational AML Advice: Advising support, onboarding, KYC, operating and other teams on the day-to-day onboarding and support queue management, effective AML/CFT resource allocations, and operational improvements, helping you maintain the overall customer experience and efficiency while remaining compliant with e-money institutions' AML/CFT requirements.
• Operational Compliance Advice: Advising compliance, management, technology, and support teams on the day-to-day compliance with e-money institutions' regulations, focusing on internal processes and critical internal controls for effective EMI compliance management.
• Risk Management Advice: Covering risk rating and methodologies, risk assessments, management, and mitigation for various risk types faced by e-money institutions, including regulatory, ML/TF, fraud, data protection, and operational risks. We help you safeguard against potential compliance breaches and comply with risk management obligations under e-money institutions' licensing requirements and other applicable laws and regulations.
• Compliance Framework Advice: To help you create or enhance your compliance management framework, identify gaps and areas of improvement, meet the e-money institutions' compliance obligations effectively, improve internal governance and reporting, and optimise them for market expansion and growth.
• E-Money Institutions' Licensing Advice: We can guide you through the licensing process, help you apply regulations to your specific circumstances and business environment, and meet e-money institutions' licensing requirements to become licensed or maintain it.
• Peer Benchmarking and Best Practices: We can help you benchmark your compliance practices against peers and applicable regulatory compliance guidance, identify areas for improvement and adopt best practices for enhanced compliance.
• Government Agencies Liaison Advice: We provide strategic guidance to senior management and compliance teams on maintaining and managing relationships with external bodies, including regulators, AML/CTF supervisors and law enforcement agencies, focusing on long-term compliance strategies and proactive engagement.
• Specific E-Money Institutions' Compliance Issues: We can help you resolve specific risk or compliance issues related to e-money institutions' regulations and compliance obligations, including but not limited to external audits and reviews, reporting, oversight, difficult clients or transactions, expansion challenges, compliance management issues, process optimisation, regulatory challenges you may encounter and more.
• Further information: You can visit our Regulatory Compliance Consulting Solutions page for a comprehensive list of advisory services we offer to e-money institutions and other licensed financial institutions, financial services providers, and regulated businesses.

 

 

Reporting and Regulatory Liaison Solutions for E-Money Institutions’ Compliance

• Regulator Liaison Management: Providing operational guidance to senior management and compliance teams on managing relationships with regulators, AML/CFT supervisors, police bodies, privacy commissioners, and other government entities. This includes handling requests for information, responding to ad-hoc regulatory inquiries, managing findings from audits and investigations, managing compliance with reporting obligations for e-money institutions and more.
• Board and Committee Reporting: Facilitating structured reporting workflows for various committees and board delegates, including risk, compliance, and audit committees, focusing on your current compliance status, deviations from your risk appetite, changes in risk ratings and any operational compliance updates to ensure that governance structures are well-informed and aligned with compliance management practices.
• Compliance Performance Metrics: Developing and presenting comprehensive compliance performance metrics to the board or relevant committees, offering insights into your compliance effectiveness and identifying points for improvement in key compliance areas, including compliance training, fraud prevention, compliance monitoring, risk rating and assessment, controls effectiveness, adherence to your compliance calendar, regulatory technology (RegTech) performance, and more.
• Internal Audit Reporting: We can help you increase the effectiveness of the internal audit to make its findings reflect your actual performance against the e-money institutions' compliance obligations. This includes developing tailored methodologies for the auditors, preparing the necessary audit evidence and reviewing audit results. The goal is to ensure that audit procedures and outcomes directly contribute to maintaining and enhancing your compliance status and internal controls' effectiveness.
• AML/CFT Reporting Compliance:  We help with the implementation of effective AML/CFT reporting processes, aligning with specific anti-money laundering regulations for internal oversight and prompt escalation of critical AML issues within your business to help the management receive a clear overview of your AML/CFT compliance status.
• Transactional Reporting: Implementing effective transactional reporting procedures to help with EMI compliance management of reporting obligations under various laws and regulations, including submitting SAR, SMR, STR, PTR, TTR, specific reportable matters under the e-money institutions' licensing requirements and other externally reportable transactions and activities.
• Internal Quality Assurance Reporting: While second-line control testing is crucial for complying with e-money institutions' regulations, including e-money institutions' licensing requirements, first-line quality assurance results are equally important for effective risk and compliance management. We help organise effective reporting lines, tailor reporting content to your specific circumstances, products, and team size, and establish a structured approach to responding to reporting outcomes.

 

 

Comprehensive EMI Compliance Management Solution

Our compliance management services include, but are not limited to, the following:

• EMI Compliance Management Leadership: We act as your Compliance Leads and Compliance Managers, fully managing compliance obligations under the applicable e-money institutions' licensing requirements, laws, regulations, industry codes, and regulatory guidance.
• Second-Line Compliance Management: We offer a full range of second-line compliance assurance solutions, including internal controls testing for operational, compliance, marketing, legal and other risks, as well as managing issue closure control testing and more.
• Supporting the Board in Strategic Compliance Management: Advising on the necessary compliance resourcing, budget, tools, role structuring, and compliance functions' structure to support your specific business objectives within your risk appetite and risk management framework.
• Compliance Project Management: Effectively coordinating between senior management, committees, legal advisers, risk and compliance functions, outsourced providers, and different departments, including product development, technology, customer support, operations, assurance, marketing, and others, to help you successfully implement compliance projects across the business.
• Customised Governance Solutions: Tailoring governance frameworks and mechanisms to fit your specific governance structure and effectively comply with e-money institutions' regulations and other applicable obligations. Whether your business is locally oriented, a start-up, undergoing expansion, part of a multinational group, has a listed parent company or is undergoing restructuring, we tailor the oversight of EMI compliance management to your business case.
• Stakeholder Management and Reporting: Reporting to the board, committees, shareholders, regulators and other stakeholders. Providing management and the board with comprehensive compliance reports that cover your compliance with e-money institutions' compliance obligations, regulatory development summary, compliance-related data and statistics, internal controls testing outcomes and more. Also covering the status of your specific compliance-related projects and compliance goals, relevant compliance KPIs, and more.
• Compliance Calendar Implementation: We design and implement compliance management programs and calendars, covering such areas of e-money institutions' compliance obligations as policy and key document reviews, control testing, risk assessment and reviews, vendor reviewers, user system access reviews, assurance activities and more.
• Managing Customer Onboarding and Due Diligence: Implementing commercially oriented and compliant processes for KYC information collecting, Know Your Business (KYB), ML/TF risk assessment, Pep and Sanctions screening, CDD and EDD, especially for higher ML/TF risk clients, to help you comply with AML/CFT compliance obligations for e-money institutions.
• AML Transaction Monitoring and Reporting: Developing and implementing a set of business-specific ML/TF alerts and red flags to detect and report suspicious transactions to comply with the e-money institutions' AML requirements without making AML/CFT compliance a hindrance to business.
• Information Requests and AML/KYC Data Sharing: Handling information requests from law enforcement agencies, AML/CTF supervisors, and other relevant AML/CTF designated entities, such as your banking partners and other essential service providers (liquidity providers, finance providers, etc.), ensuring that you are fully supported in all AML/CTF compliance-related communications.
• Business Expansion Support: Providing support for your business expansion objectives, recognising and assessing new risks, developing and implementing controls and mitigations for them, as well as addressing new compliance obligations and putting in place practical tools and systems to manage them.
• E-Money Institutions' Operational Compliance: Including but not limited to:
  • On-the-Ground Compliance: Conducting compliance management meetings, organising routine and ad hoc compliance reporting, overseeing mitigations and controls testing, leading adjustments and enhancements to your internal controls and protocols when required.
  • Compliance Process and Operations Building: Developing effective and compliant procedures and processes to implement your policies, support your operations across different teams and mitigate operational, regulatory and other risks.
  • Outsourced Provider Performance Monitoring: Setting up initial due diligence and ongoing review frameworks for your outsourced providers to help you meet the required service standards for outsourcing under various e-money institutions' compliance obligations, including e-money institutions' licensing requirements.
  • Incident Management and Reporting: We can help you set up effective processes for incident reporting, escalations, and management at different levels of your business.

 

E-Money Institutions’ Compliance Assurance 

Our services include:

• Compliance Assurance Programs:  We can design and implement your compliance assurance program to maintain enhanced oversight of your compliance with both e-money institutions' regulations and your internal compliance and risk appetite thresholds.
• Organisation-Wide Risk Assessments: Helping you focus on the specific risks faced by your business, considering its size, products, client types, jurisdictions of operation, delivery channels, financial institutions you interact with, available technology, and other tools. This includes assessing available mitigations, controls, their effectiveness, residual risk ratings, and the plan to move forward.
• Internal Controls Design: We can develop internal controls for various risk types, including regulatory, fraud, operational, strategic, financial, and other risks. Please visit our Internal Controls Design page for more information. 
• Assurance Testing: We conduct assurance testing to verify that the business complies with its policies, procedures, and e-money institutions' compliance obligations, including e-money institutions' licensing requirements. We also assess whether your internal controls effectively mitigate existing risks, including those required to be monitored under the applicable e-money institutions' regulations. This process includes a compliance controls testing report and, if necessary, a gap analysis.
• Compliance Quality Assurance: We go beyond merely meeting regulatory requirements. We focus on evaluating and enhancing your risk and compliance management processes to ensure they align with your current and future goals, business model, your risk analysis, your current client inflow, and more. We also suggest which compliance processes you can use to meet your goals. Here is an example of this service in the AML/CFT area.
• Assurance Reporting: Compiling testing findings and issuing comprehensive compliance assurance reports, which include:

• Identification of any deficiencies or control weaknesses, with clear explanations and potential root cause analysis.
• Recommendations for corrective actions to address identified issues and enhance compliance effectiveness.
• Evaluation of the overall effectiveness of your internal controls and regulatory compliance monitoring program against your desired assurance level.

• Regulatory Inspection Readiness: We can help your business prepare for external audits and regulatory inspections, reducing the risk of adverse findings related to e-money institutions' compliance obligations. This includes conducting mock inspections to identify gaps, reviewing documentation and record-keeping practices to ensure all relevant materials are well-organised and readily accessible, and training staff on their roles in the inspection process. We assist in identifying any missing information and weak points, provide interview preparation, and more to ensure readiness for auditor or regulator review.
• Further information: You can visit our Compliance Assurance Solutions page for more information on our third-line compliance assurance review solutions.

 

Compliance Remediation Solutions

Our focus areas include:

• Compliance Remediation Advice: Assisting e-money institutions in effectively addressing and rectifying compliance issues, from minor breaches to significant regulatory challenges, including warnings and action plans.
• Remediation Plan Development: Following the independent review, we assist in analysing the findings to identify necessary remedial actions. We then support e-money institutions in devising a detailed plan outlining these actions for submission to your regulator or an AML/CFT supervisor, ensuring the plan is both actionable and compliant with regulatory expectations.
• Remediation Plan Commitment: We help e-money institutions complete their remediation plans and prevent non-compliance recurrence.
• Executive Attestation Support: Our services include assisting senior executives in preparing the required attestations to your regulator. This involves confirming that all necessary remedial actions have been undertaken and adequate compliance measures are in place, supported by comprehensive documentation and evidence. This option covers assistance with the removal of any licensing restrictions.
• Further Information: For more information, you can visit our Compliance Remediation Solutions page.

 

 

Internal Controls Testing and EMI Compliance Management

When it comes to reality versus a nice policy or procedure with nothing else to show for it, it’s often a case where a policy says A, but reality says B. One might ask, why didn’t we test our internal controls before? Or, why didn’t we do it properly? There’s nothing worse than faking compliance instead of actually doing it.

Our second line of compliance defence solutions covers the development, testing, and enhancement of a wide range of controls to ensure compliance with various laws and regulations governing e-money institutions' compliance obligations.

We go beyond merely quoting e-money institutions' regulations or a selection of licensing requirements, then adding Excel sheets painted in different colours as a supposed source of truth with nothing to show for it.

• We test them.
• We link them to your risk appetite and core risk management documentation.
• We provide relevant suggestions and analysis tailored to your business.

Some of our focus areas for testing the e-money institutions' compliance requirements include:

 

Regulatory Compliance and Licensing Controls

• EMI Compliance Management Program: E-money institutions should establish robust compliance management systems, including conflict of interest management and staff training, to meet regulatory requirements.
• Liquidity Management: E-money providers should ensure sufficient liquidity to meet operational needs and maintain operational efficiency.
• Capital Adequacy: Electronic money institutions should maintain adequate capital to cover operational risks, ensuring financial stability.
• Financial Auditing: Digital money issuers should engage auditors to conduct regular financial audits to verify the accuracy of financial statements and ensure compliance with regulatory standards.
• Cross-Border Application of Regulations: E-money institutions should comply with specific guidelines and rules regulating the cross-border application of national e-money institutions' licensing requirements when offering services to clients in multiple jurisdictions.

 

Operational Oversight Controls

• Outsourcing Oversight: E-money businesses should maintain control and oversight over outsourced functions to ensure they do not compromise regulatory obligations, customer data security, or other critical areas.
• Risk Management: E-money providers should establish comprehensive risk frameworks and procedures to identify, assess, and manage operational risks effectively.
• Governance Arrangements: Electronic money institutions should implement effective governance structures to oversee operations and ensure responsible management and decision-making.
• Senior Management Accountability: Digital money issuers should assign specific responsibilities to senior managers to ensure accountability for conduct and competence.
• Operational Resilience: E-money institutions should ensure the resilience of critical business services, planning for continuity during disruptions.
• Technology Risk Management: E-money institutions should manage IT and cybersecurity risks, particularly for those engaged in electronic trading or reliant on sophisticated IT systems.
• Information Security Management: E-money businesses should ensure the confidentiality, integrity, and availability of customer data to meet regulatory requirements.
• Business Continuity and Disaster Recovery (BCDR): E-money institutions should implement robust BCDR plans to ensure the continuation of critical operations during disruptions.
• Digital Lending and Automation: E-money providers should implement controls for digital platforms and automated decision-making processes to comply with regulatory standards and provide fair outcomes.

 

Market Integrity and Transparency Controls

• Market Conduct Standards: E-money institutions should ensure that market conduct is fair, transparent, and free from abuse, including manipulation or insider trading.
• Fair Dealing Principles: E-money businesses should adhere to principles that guarantee fair treatment of clients, with clear communication and transparent dealings.
• Conduct and Disclosure Standards: Electronic money institutions should maintain high standards of conduct and ensure that disclosures to clients are clear, accurate, and effective.
• Service Provision Standards: E-money providers should deliver financial services efficiently, honestly, and fairly to ensure client protection.
• Product Governance: Digital money issuers should establish adequate arrangements for product design, approval, and review to meet regulatory requirements and client needs.
• Client Asset Protection: E-money institutions should protect client assets by segregating them from company funds and adhering to clear rules on their use and handling.
• Dispute Resolution: E-money businesses should have proper mechanisms for resolving disputes and compensating clients, especially retail clients.
• Advertising Standards: E-money providers should adhere to regulations that govern the truthfulness and fairness of advertising e-money products.

 

Resource Management Controls

• Professional Competence: E-money institutions should ensure that key personnel possess the necessary competence, knowledge, and skills to perform their roles effectively.
• Adviser and Representative Competence: Electronic money institutions should ensure that advisers and representatives providing financial services receive adequate training and demonstrate competence.
• Training and Development: E-money businesses should provide ongoing training to ensure staff remain up-to-date with regulatory requirements and industry best practices.
• Regulatory Technology (RegTech): E-money institutions are expected to utilise advanced RegTech solutions to streamline compliance processes and ensure effective monitoring and reporting.

EMI Compliance Management and Reporting Controls

• Comprehensive Transaction Reporting: E-money institutions should maintain detailed oversight over transactions to ensure comprehensive monitoring and regulatory compliance.
• Regulatory Reporting: E-money providers should submit regular reports to regulatory authorities detailing compliance status and other relevant activities.
• Record-Keeping: Electronic money institutions should maintain accurate records of all transactions to ensure transparency and accountability under applicable regulations.
• Sustainability Reporting: E-money institutions are expected to establish controls for reporting on ESG initiatives to comply with growing regulatory and consumer expectations.
• Impact Reporting: Digital money issuers are expected to assess and disclose the social and economic impact of their activities to align with regulatory expectations and social responsibility goals.

Product and Service Management Controls

• Product Suitability: E-money institutions should ensure that products are appropriate for customers, considering their financial situation and needs.
• Product Lifecycle Oversight: Electronic money institutions should manage products from design to distribution to meet regulatory requirements and maintain market integrity.
• Execution Quality: E-money businesses should ensure efficient processing of transactions and provide high-quality service to customers.
• Data Protection and Privacy: E-money providers should adhere to data protection laws and ensure the privacy of customer data in compliance with regulatory standards.
• Agile Product Development: Digital money issuers should enable rapid development and deployment of new products to meet market demands and regulatory requirements.
• Accessibility and Inclusivity: E-money institutions should ensure that products and services are accessible to all customers, aligning with broader social responsibility goals.

 

Transactional Controls

• Know Your Customer (KYC): E-money institutions should implement KYC procedures to verify depositor identities and comply with AML regulations.
• Customer Onboarding: E-money businesses should implement efficient onboarding procedures to ensure a seamless process for new clients, including digital verification methods.
• Transaction Verification: E-money providers should ensure the authenticity of transactions through robust verification procedures.

 

E-money Institutions Licensing Solutions

• Financial Licensing Application Support: We provide comprehensive support for a wide range of e-money institutions' licensing applications, including:

• Australia: Assisting with the application for an Australian Financial Services Licence (AFSL), ensuring compliance with ASIC regulations.
• United States: Providing consultancy for obtaining state-specific Money Transmitter Licenses and ensuring compliance with federal regulations, including the Electronic Fund Transfer Act (EFTA).
• United Kingdom: Supporting e-money institutions in obtaining FCA authorisation under the Electronic Money Regulations 2011.
• Singapore: Assisting with the application process for a licence under the Payment Services Act, ensuring compliance with MAS regulations.
• European Union: Advising on compliance with the E-Money Directive (EMD) and the Payment Services Directive (PSD2).
• Cayman Islands: Assisting e-money institutions with obtaining a license under the Money Services Law, ensuring compliance with the Cayman Islands Monetary Authority (CIMA) regulations.
• Bermuda: Supporting e-money institutions in Bermuda with the licensing process under the Digital Asset Business Act 2018, ensuring compliance with BMA regulations.
• Gibraltar: Guiding e-money institutions through the licensing process under the Financial Services (Electronic Money) Regulations 2011, ensuring compliance with GFSC regulations.
• British Virgin Islands: Assisting e-money institutions with obtaining licences under the Financing and Money Services Act, ensuring compliance with BVI FSC regulations.
• Seychelles: Supporting e-money institutions in the Seychelles with the licensing process under the Financial Services Authority Act, ensuring compliance with FSA regulations.
• Vanuatu: Guiding e-money institutions through the licensing process under the Financial Dealers Licensing Act, ensuring compliance with VFSC regulations.
• Other jurisdictions.

• International Governance Alignment: We provide strategic advice on aligning governance models and governance structures for e-money institutions operating across multiple jurisdictions to meet diverse regulatory expectations while maintaining operational efficiency and regulatory compliance.

 

 

Policies and Procedures for EMI Compliance Management 

• Compliance Policies and Core Documents: We develop, enhance, and implement a set of core policies, manuals, frameworks, and procedures for effective EMI compliance management.
• Effective Procedures for EMI Compliance Management: We draft and enhance a detailed set of procedures and protocols to meet the distinct needs of your business, focusing on efficient compliance, your business goals, and applicable e-money institutions' compliance requirements.
• Examples: These policies and procedures include, but are not limited to:

 

Operational Compliance

• Compliance Management Frameworks
• Compliance Monitoring Programs
• Compliance Calendars and Checklists
• Complaints Handling and Dispute Resolution Policies
• Compliance Training Manuals and Programs, as part of our regulatory compliance training solutions
• Obligation Registers
• Incident Reporting Policies and Procedures
• Outsourcing Policies and Vendor Risk Management policies as part of our outsourced provider's compliance management solutions
• New Client Account Opening Policies and Procedures, as part of our customer onboarding solutions

 

Governance and Oversight

• Board Charters, Risk, Audit and Compliance Committee Charters, as part of our corporate governance solutions
• Codes of Conduct
• Delegations Registers
• HR Manuals and Policies
• ESG Compliance Policies
• Conflict of Interest Policies

 

Risk Management

• Risk Management Frameworks as part of our risk management solutions
• Risk Assessment Guidelines and Methodologies
• Internal Control Testing Methodologies
• Risk Registers and specialised risk registers like Health and Safety Risk Registers
• Business Continuity and Disaster Recovery (BCDR) Policies

 

Audit and Assurance

• Compliance Assurance Programs as part of our compliance assurance solutions
• Internal Audit Policies and Programs as part of our internal control testing solutions
• Regulatory Reporting Procedures

 

Client and Market Conduct

• Marketing and Advertising Policies
• Deposit Interest Rate Policy and Procedures

 

AML/CFT and Financial Crime Compliance

• AML/CFT Compliance Programs
• AML/CFT Risk Assessment
• Whistleblowing Policies
• Sanctions Compliance policies and procedures
• Fraud Prevention Protocols and Controls as part of our fraud prevention solutions
• ABC Policies

 

Privacy and Data Management

• Client Data Protection Policies
• Record-keeping Policies and Procedures and/or Data Governance Policies as part of our record-keeping compliance solution
• External Privacy Policies
• Internal Data Protection Compliance Programs

 

 

Compliance Training and Capacity Building

We focus on practical compliance and the application of training to real-world compliance scenarios and challenges that e-money institutions generally face. Our services include:

• Customised Compliance Training Solutions:  Specialised compliance training sessions for various teams, including management, compliance, operations, sales, and customer relations, focusing on e-money institutions' regulations, applying EMI compliance management practices to your circumstances, risk awareness, and more.
• Up-to-date Regulatory Compliance Updates:  Keeping compliance officers, managers, CROs, COOs, and other Risk and Compliance team members informed of changes in e-money institutions' licensing requirements and regulations, AML/CFT updates, and changes in regulatory guidance.
• Data Analysis for Effective Compliance Monitoring: Covering training on compliance-related, data-based analysis and its results, including risk rating, internal control adjustments, resource and focus reallocation, and more.
• Workshops on Emerging AML Trends and Red Flags: Updating on the new AML trends, red flags, typologies, and AML/CFT requirements for e-money institutions. For more information, please visit our AML/CFT Training Solutions page.
• Practical Workshops: Interactive workshops focused on effective and goal-oriented e-money institutions' compliance, capacity planning, and resource allocation, covering:

• E-Money institutions' regulations
• Internal and external compliance reporting
• Effective governance over risk and compliance functions
• Organisation-wide risk assessment, risk rating methodologies and the development, management, and testing of corresponding internal controls, including controls testing methodologies and practical techniques.
• E-money institutions' compliance reality, including outsourced provider monitoring, UAV management, incident management, product suitability assessments, advertising and marketing compliance, improvements in the client onboarding journey, transaction monitoring processes, and more.

• Further information: You can visit our Compliance Training Solutions page for more information on the compliance training services we offer to licensed financial institutions and financial service providers.

 

E-Money Institutions and AML/CTF Obligations

We offer a complete set of solutions covering e-money institutions' anti-money laundering (AML), financial crime and counter-terrorism financing (CTF) compliance. Our solutions include:

• Customer due diligence, screening, and customer onboarding solutions
• Development of transaction monitoring frameworks tailored to e-money institutions' specific ML/TF red flags and your business specifications
• AML advisory covering e-money institutions' compliance issues and challenges
• Drafting, testing, and updating AML policies and procedures
• AML training and capacity building
• Managed AML compliance solutions for e-money institutions
• Internal and statutory AML/CFT audit solutions for e-money institutions
• Financial crime prevention framework development focusing on common fraud risks faced by e-money institutions
• For more information about effective E-money AML measures, please visit our specialised AML/CFT Solutions Page for E-Money Institutions

 

E-Money Institutions’ Compliance Technology Integration

Our services cover compliance aspects concerning the integration of technology for risk and compliance e-management, transactional reporting (where applicable), usage of AI, technology outsourcing, and compliance aspects of third-party risk management for e-money institutions, including:

• Needs Assessment
• Compliance Technology Selection: Based on your budget, products, available operational and technical resources, and the applicable e-money institutions' compliance obligations
• Implementation assistance across the organisation
• Streamlining operational workflows: For routine compliance tasks like data collection, reporting, and risk assessments
• AML/CFT Compliance Technology: Covering customer digital onboarding, E-KYC, PEP and sanctions screening, transaction monitoring, etc.
• Integration of e-money institutions' compliance obligations into an effective CRM system
• Record-Keeping Obligations: Helping you choose and integrate the necessary tools to comply with the record-keeping requirements under various laws and e-money institutions' regulations

 

Data Management and Information Privacy Solutions

• Data Governance and Compliance:  Assisting e-money institutions in establishing robust data governance procedures, programs, and protocols that align data collection, storage, and usage practices with relevant data privacy regulations, such as GDPR, CCPA, and other applicable laws. These measures safeguard sensitive client and business information from unauthorised access, breaches, and misuse.
• Privacy Policy Compliance Monitoring: Helping you implement privacy policies that reflect the latest data protection legislation, supported by continuous compliance monitoring tools to maintain the highest data privacy standards.
• Record Maintenance Protocols:  We assist in developing and implementing effective procedures for maintaining necessary records, covering e-money institutions' compliance with applicable regulatory reporting standards and EMI reporting requirements.
• Record Availability and Inspection Readiness: E-money institutions' regulations often require records to be readily available for inspection by regulators, AML/CFT supervisors, tax agencies, and other relevant authorities. This extends to information kept by your outsourced service providers. We help you organise your record-keeping processes to meet these needs.

 

ISO Standards and E-Money Institutions’ Compliance

• Cross-Reference Mapping: Integrating ISO standards such as ISO 27001, ISO 9001, and ISO 22301 into an existing compliance framework and linking specific sections of ISO standards to corresponding procedures in your internal policies and procedures.
• Pre-Audit Preparation: Coordinating ISO controls testing across different parts of the business.
• Leading evidence collection across the different departments to cover relevant compliance areas such as planning, governance, organisational controls, operational controls, technological controls, and physical controls through structured workflows.
• Digital Compliance Repository: Helping you utilise a centralised digital repository for storing all compliance-related documents and evidence, making it easily accessible for audit purposes and compliance verification.
• ISO Audit Liaison:  Acting as a liaison between your team and the auditors, coordinating information requests, and ensuring all the necessary documentation is readily available.
• Post-Audit Remediation Management: We can lead the implementation of your remediation plan and support corrective actions to address all audit findings effectively.

 

Regulatory Change Management Solutions

Empower Your Business with Proactive Regulatory Change Management:

• Stay Ahead of the Curve:  We actively monitor regulatory updates from global financial authorities like MAS, ASIC, FMA, FCA, SEC, and other regulators for e-money institutions' compliance changes and updates to evaluate the implications of regulatory changes.
• Impact Assessment and Mitigation Strategies: We analyse the potential impact of regulatory changes on EMI compliance management frameworks and operational processes. We then collaborate with you to develop effective mitigation strategies that support continued compliance and minimise disruption.
• Seamless Implementation and Change Management:  We guide e-money institutions through necessary process adjustments, update internal policies and procedures, facilitate a smooth transition through regulatory changes, and assist with effective communication with impacted stakeholders.