Specialised Solutions for Money Remitters’ Compliance Management

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

• Your payment solutions and related products
• Your commercial objectives
• Your business goals
• 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 money remitters' 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, money remitters' obligations under privacy laws, anti-money laundering and counter-terrorist financing (AML/CFT) laws, fair trading laws, and more.
• Money remitters' 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 money remitters, 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
  • Anti-fraud measures
  • Sanctions Compliance
  • Customer Protection Regulations
  • Electronic Money Regulations

 

What Jurisdictions Do Our Compliance Solutions Cover?

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

• Australia: Where money remittance businesses should register with AUSTRAC under the AML/CTF Act 2006. When financial services or NCP products are offered, an AFSL from ASIC may also be required.
• United States: Where money remittance businesses should obtain a Money Transmitter License (MTL) from individual state regulators, with additional registration with the Financial Crimes Enforcement Network (FinCEN) under the Bank Secrecy Act.
• United Kingdom: Where money remittance businesses should be licensed or registered with the FCA under the Payment Services Regulations 2017, depending on their business model. Compliance with AML regulations is mandatory.
• Singapore: Where money remittance businesses should be licensed by the Monetary Authority of Singapore (MAS) under the Payment Services Act 2019. This includes compliance with stringent AML/CFT requirements.
• New Zealand: Where money remittance businesses should be registered as Financial Service Providers (FSP) and comply with the Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Act. Licensing is not required.
• European Union: Where money remittance businesses should comply with the EU's Payment Services Directive (PSD2) and register with the relevant national authorities. Licensing requirements vary by member state.
• Offshore Financial Centres, including:

• Seychelles: Where money remittance businesses should obtain a license from the Financial Services Authority (FSA) under the Anti-Money Laundering Act 2006.
• Cayman Islands: Where money remittance businesses should obtain a license through the Cayman Islands Monetary Authority (CIMA) under the Money Services Law.
• British Virgin Islands (BVI): Where money remittance businesses should obtain a license through the BVI Financial Services Commission (FSC) under the Financing and Money Services Act 2009.
• Belize: Where money remittance businesses should obtain a license through the International Financial Services Commission (IFSC) under the Money Laundering and Terrorism (Prevention) Act.
• Mauritius: Where money remittance businesses should obtain a license through the Financial Services Commission (FSC) under the Financial Intelligence and Anti-Money Laundering Act 2002.
• Labuan (Malaysia): Where money remittance businesses should obtain a license through the Labuan Financial Services Authority (LFSA) under the Labuan Financial Services and Securities Act 2010.
• Gibraltar: Where money remittance businesses should obtain a license through the Gibraltar Financial Services Commission (GFSC) under the Financial Services (Electronic Money) Regulations 2011.

 

 

What Types of Money Remitters Do We Support?

Our compliance solutions for money remitters and payment providers cover the following types of financial institutions:

• Peer-to-Peer Payment Services: Platforms allowing individuals to transfer money directly to each other.
• Domestic Money Remitters: Businesses that provide money remittance services within a single country.
• Consumer Money Remitters: Businesses that provide money transfer services to individual consumers for personal, family, or household purposes.
• Commercial Money Remitters: Businesses that offer money transfer services to other businesses for operational needs, including payroll, vendor payments, and international transactions.
• Mobile Payment Providers: Businesses that specialize in mobile payments and mobile money transfer services.
• Cryptocurrency Remittance Platforms: Businesses providing money transfer services involving cryptocurrency remittances.
• E-Wallet Providers: Businesses that offer digital wallets for storing and transferring money electronically.
• Prepaid Card Issuers: Businesses issuing prepaid cards that can be used for money transfers, purchases, and withdrawals.
• Remittance Service Providers: Businesses specializing in international money transfers.
• Foreign Exchange Dealers: Businesses facilitating the exchange of different currencies for individuals and businesses.
• International Money Remitters: Businesses that facilitate cross-border money transfers.
• Digital Money Remitters: Businesses that offer online and mobile money transfer services

 

 

Money Remitters’ Compliance Advisory

Our focus areas include:

• Detailed Compliance Advice: Covering money remitters' compliance management issues across the first, second, and third lines, as well as matters related to effective compliance with financial markets regulations and money remitters' 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 money remitters' AML/CFT requirements.
• Operational Compliance Advice: Advising compliance, management, technology, and support teams on the day-to-day compliance with money remitters' regulations, focusing on internal processes and critical internal controls for effective money remitters' compliance management.
• Risk Management Advice: Covering risk rating and methodologies, risk assessments, management, and mitigation for various risk types faced by money remitters, 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 money remitters' 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 money remitters' compliance obligations effectively, improve internal governance and reporting, and optimise them for market expansion and growth.
• Money Remitters' Licensing Advice: We can guide you through the licensing process, help you apply regulations to your specific circumstances and business environment, and meet money remitters' 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 Money Remitters' Compliance Issues: We can help you resolve specific risk or compliance issues related to money remitters' 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 money remitters and other licensed financial institutions, financial services providers, and regulated businesses.

 

 

Reporting and Regulatory Liaison Solutions for Money Remitters’ 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 money remitters 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 money remitters' 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 money remitters' compliance management of reporting obligations under various laws and regulations, including submitting SAR, SMR, STR, PTR, TTR, specific reportable matters under the money remitters' licensing requirements and other externally reportable transactions and activities.
• Internal Quality Assurance Reporting: While second-line control testing is crucial for complying with money remitters' regulations, including money remitters' 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 Compliance Management Solution for Money Remitters

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

• Money Remitters' Compliance Management Leadership: We act as your Compliance Leads and Compliance Managers, fully managing compliance obligations under the applicable money remitters' 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 money remitters' 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 money remitters' 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 money remitters' 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 money remitters' 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 money remitters.
• 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 money remitters' 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.
• Money Remitters' 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 money remitters' compliance obligations, including money remitters' 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.

 

Money Remitters’ 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 money remitters' 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 money remitters' compliance obligations, including money remitters' licensing requirements. We also assess whether your internal controls effectively mitigate existing risks, including those required to be monitored under the applicable money remitters' 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 money remitters' 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 money remitters 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 money remitters 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 money remitters 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 Money Remitters’ 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 money remitters' compliance obligations.

We go beyond merely quoting money remitters' 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 money remitters' compliance requirements include:

 

Regulatory Compliance and Licensing Controls

• Compliance Management: Money remitters should have robust compliance management systems, including conflict of interest management and staff training, to meet regulatory requirements.
• Liquidity Management: Money remittance providers are expected to maintain sufficient liquidity to ensure operational stability and meet payout demands.
• Capital Adequacy: Money remitters should maintain adequate capital to cover operational and credit risks, aligning with relevant prudential standards.
• Financial Reporting and Auditing Requirements: Money remitters should adhere to the financial reporting and auditing requirements specified by the applicable licensing regime (if any), ensuring transparency and regulatory compliance.
• Cross-Border Application of Regulations: Money remitters are expected to adhere to international regulations when operating across multiple jurisdictions.
• Fee Disclosure and Pricing Practices: Money remittance providers should implement clear and transparent fee disclosure practices to ensure customers are fully aware of all costs associated with their services.

Operational Oversight Controls

• Outsourcing Oversight: Money remittance businesses should maintain oversight of outsourced functions, such as IT services and customer support, to ensure compliance with regulatory standards.
• Risk Management: Payment providers are expected to implement comprehensive risk management frameworks to identify, assess, and mitigate operational and financial risks.
• Governance Arrangements: Money remittance providers should establish effective governance structures to oversee operations and ensure responsible decision-making.
• Senior Management Accountability: Senior management in money remittance businesses should take ownership of compliance and risk management practices.
• Operational Resilience: Money remitters are expected to ensure the resilience of critical business services, with continuity plans for disruptions. This includes Business Continuity and Disaster Recovery. Money remittance providers should establish and maintain business continuity and disaster recovery plans to ensure ongoing operations during disruptions.
• Technology Risk Management: Payment providers should manage technology risks, including cybersecurity threats and data integrity, to protect against potential breaches.

 

Market Integrity and Transparency Controls

• Market Conduct Standards: Money remittance providers are expected to ensure fair and transparent practices in their operations, including clear and accurate communication with clients.
• Fair Dealing Principles: Payment providers should adhere to principles that guarantee fair treatment of clients, including transparent terms and conditions.
• Conduct and Disclosure Standards: Money remittance businesses are expected to maintain high standards of conduct and ensure clear disclosures to clients about their services.
• Service Provision Standards: Money remittance providers should deliver services efficiently, honestly, and fairly, ensuring client protection.
• Client Asset Protection: Money remitters are expected to safeguard client funds, ensuring they are segregated from operational funds.
• Exchange Rate Transparency: Money remittance providers should disclose exchange rates transparently to ensure customers are aware of the rates applied to their transactions.

Resource Management Controls

• Resource Adequacy: Payment providers should maintain adequate financial, technological, and human resources to support their operations and comply with regulatory requirements.
• Professional Competence: Money remittance businesses are expected to ensure that staff possess the necessary skills and knowledge to perform their roles effectively.

Reporting Controls

• Regulatory Reporting: Money remittance providers should submit regular reports to regulatory authorities, detailing financial status and compliance with AML/CFT measures.
• Record-Keeping: Money remittance businesses are expected to maintain accurate and accessible records of transactions and client interactions to facilitate audits and regulatory reviews.

Transactional Controls

• Authorization and Verification Procedures: Payment providers should verify customer identities and transactions, aligning with AML/KYC regulations.
• Conflict of Interest in Transactions: Money remittance businesses are expected to identify and manage potential conflicts of interest, ensuring decisions are made in the best interests of clients.
• Payment Processing Security: Payment providers are expected to enhance controls around payment processing to ensure secure, efficient, and compliant transactions, including adherence to PCI DSS standards.
• Mobile Money Transfer: Payment providers specializing in mobile money transfers should ensure compliance with mobile payment regulations and implement robust security measures to protect customer transactions.

 

Market Integrity and Transparency Controls

• Consumer Rights and Redress: Money remittance providers should implement procedures to protect consumer rights and provide mechanisms for redress in case of disputes.
• Dispute Resolution: Money remittance providers should implement effective mechanisms for resolving customer disputes, ensuring timely and fair outcomes.

Data Protection and Privacy

• Data Privacy Compliance: Money remittance providers should implement controls to ensure compliance with data protection regulations such as GDPR, including data minimization, consent mechanisms, and secure data storage.
• Client Data Access and Portability: Money remittance businesses are expected to establish procedures allowing clients to access their data or request data portability in line with privacy regulations.

Emerging Technologies and Innovation

• Cryptocurrency and Blockchain Integration: For money remittance providers accepting cryptocurrency or utilizing blockchain technology, controls should be in place to manage associated risks and ensure compliance with AML regulations.
• Artificial Intelligence and Machine Learning Use: If employing AI/ML technologies, money remittance businesses should ensure transparency, fairness, and data protection in their application.

Licensing and Registration Solutions for Money Remittance Businesses

Financial Licensing Application Support: We provide comprehensive support for a wide range of money remitters' licensing and registration applications, including:

• Australian Money Remittance Licene and Registration: We assist money remittance businesses in registering with AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, ensuring compliance with Australian regulatory standards for designated remittance services. If required, we also support applications for an Australian Financial Services Licence (AFSL) from ASIC where non-cash payment products or financial services are involved.
• United States Money Transmitter Licensing: Our services include guiding businesses through the process of obtaining a Money Transmitter License (MTL) from individual state regulators and registering with the Financial Crimes Enforcement Network (FinCEN) under the Bank Secrecy Act, ensuring comprehensive AML/CFT compliance.
• UK Money Remittance Registration: We assist with FCA authorisation or registration under the Payment Services Regulations 2017, depending on the business model.
• Singaporean Money Remittance Licensing: We support licence applications under the Payment Services Act 2019 with the Monetary Authority of Singapore (MAS), covering relevant payment service types and AML/CFT obligations.
• New Zealand Financial Service Provider Registration: We help money remittance businesses register as Financial Service Providers (FSP) and comply with the Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Act, navigating New Zealand's regulatory framework without the need for a specific license.
• EU Money Remittance Registration: Our services cover guiding businesses through compliance with the EU's Payment Services Directive (PSD2) and registration with the relevant national authorities, tailored to the specific licensing requirements of each member state.
• Seychelles Money Remittance Licensing: We assist businesses in obtaining a license from the Financial Services Authority (FSA) under the Anti-Money Laundering Act 2006, ensuring compliance with Seychelles' regulatory standards.
• Cayman Islands Money Remittance Licensing: Our team provides support for obtaining a license through the Cayman Islands Monetary Authority (CIMA) under the Money Services Law, ensuring adherence to local AML/CFT regulations.
• BVI Money Remittance Licensing: We guide businesses through the process of obtaining a license from the BVI Financial Services Commission (FSC) under the Financing and Money Services Act 2009, ensuring compliance with BVI's regulatory standards.
• Belize Money Remittance Licensing: Our services include assistance in obtaining a license from the International Financial Services Commission (IFSC) under the Money Laundering and Terrorism (Prevention) Act, ensuring compliance with Belize's regulatory framework.
• Mauritius Money Remittance Licensing: We help businesses obtain a license from the Financial Services Commission (FSC) under the Financial Intelligence and Anti-Money Laundering Act 2002, ensuring adherence to Mauritius' regulatory requirements.
• Labuan (Malaysia) Money Remittance Licensing: Our team assists with obtaining a license from the Labuan Financial Services Authority (LFSA) under the Labuan Financial Services and Securities Act 2010, ensuring compliance with local AML/CFT standards.
• Gibraltar Money Remittance Licensing: We provide guidance for obtaining a license from the Gibraltar Financial Services Commission (GFSC) under the Financial Services (Electronic Money) Regulations 2011, ensuring adherence to Gibraltar's regulatory standards.
• Other jurisdictions.

2. International Governance Alignment: We provide strategic advice on aligning governance models for money remittance businesses operating across multiple jurisdictions to meet diverse regulatory expectations while maintaining operational efficiency and regulatory compliance.

Policies and Procedures for Money Remitters’ Compliance Management 

• Compliance Policies and Core Documents: We develop, enhance, and implement a set of core policies, manuals, frameworks, and procedures for effective money remitters' compliance management.
• Effective Procedures for Money Remitters' 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 money remitters' 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
• Margin Account Negative Balance Write-Off Procedures
• 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
• Transaction-Specific Procedures:

• • Large Transaction Monitoring: Procedures for monitoring and reporting large transactions to comply with AML regulations
  • Currency Exchange Controls: Guidelines for managing currency exchange activities in compliance with regulatory standards
  • Remittance Flow Tracking: Systems for tracking the flow of remittances to ensure transparency and compliance

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD):

• CDD Procedures: Standard procedures for conducting customer due diligence
• EDD Procedures: Enhanced measures for high-risk customers and transactions

 

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
• Cybersecurity Risk Management 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
• Staff Dealing and Insider Trading Policies
• Margin Dealing Conduct Policies and Procedures
• Fair Lending Policies

 

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 Program

 

Compliance Training and Capacity Building

We focus on practical compliance and the application of training to real-world compliance scenarios and challenges that money remitters 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 money remitters' regulations, applying money remitters' 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 money remitters' 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 money remitters. For more information, please visit our AML/CFT Training Solutions page.
• Practical Workshops: Interactive workshops focused on effective and goal-oriented money remitters' compliance, capacity planning, and resource allocation, covering:

• Money remitters' 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.
• Money remitters' 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.

 

Money Remitters and AML/CTF Compliance

We offer a complete set of solutions covering money remitters' 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 money remitters' specific ML/TF red flags and your business specifications
• AML advisory covering money remittance providers' compliance issues and challenges
• Drafting, testing, and updating AML policies and procedures
• AML training and capacity building
• Managed AML compliance solutions for money remmitance providers
• Internal and statutory AML/CFT audit solutions for money remitters
• Financial crime prevention framework development focusing on common fraud risks faced by money remitters.
• For more information, please visit our specialised AML/CFT Compliance Solutions page for Money Remmitance Providers

 

Money Remitters’ 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 money remitters, including:

• Needs Assessment
• Compliance Technology Selection: Based on your budget, products, available operational and technical resources, and the applicable money remitters' 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 money remitters' 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 money remitters' regulations

 

Data Management and Information Privacy Solutions

• Data Governance and Compliance:  Assisting money remitters 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 money remitters' compliance with applicable regulatory reporting standards and reporting requirements.
• Record Availability and Inspection Readiness:  Money remitters' 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 Money Remitters’ 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 money remitters' 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 money remitters' 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 money remitters through necessary process adjustments, update internal policies and procedures, facilitate a smooth transition through regulatory changes, and assist with effective communication with impacted stakeholders.