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The control stack regulated businesses are examined on.
Customer due diligence through suspicious-activity reporting — implemented, integrated and tuned. Tooling, not legal advice.
We are engineers. Your compliance function owns the decisions; we own whether the system can execute them.
Most AML failures examined by regulators are not policy failures. They are implementation failures.
The policy said screen against sanctions lists; the screening ran against a stale list. The policy said monitor transactions; the thresholds were vendor defaults nobody tuned, generating thousands of alerts nobody could clear. The policy was fine. The system could not execute it.
That gap is where we work. We do not give legal advice, we do not determine whether a report must be filed, and we do not sign off on your risk appetite — those belong to your MLRO and your counsel. We make sure the tooling does what your policy already says it does, and that you can prove it.
The stack, in the order a customer moves through it.
- Onboarding — CDD
- Identity verification (document authentication plus biometric liveness), data capture, and initial customer risk rating on a risk-based approach.
- Enhanced due diligence
- Source of funds and source of wealth, beneficial ownership (UBO) resolution, and structured review workflows for higher-risk relationships.
- Sanctions screening
- Against OFAC SDN, EU consolidated, UN and HM Treasury lists. List freshness monitored; fuzzy-matching thresholds tuned; false positives triaged rather than tolerated.
- PEP screening
- Politically exposed persons identified and placed under enhanced monitoring, with defined de-listing rules.
- Adverse media
- Negative-news screening with relevance filtering, so an analyst reads signal instead of noise.
- Transaction monitoring
- Rule-based detection against known typologies plus behavioural analytics. Thresholds tuned to your book — not left at vendor defaults.
- Case management
- Investigation workflow with a complete, immutable audit trail and defined escalation to the MLRO.
- Regulatory reporting
- SAR/STR generation and filing workflows (for example FinCEN), plus recordkeeping that survives examination.
- Ongoing monitoring
- Periodic review and trigger-based re-KYC, so a file does not go stale between onboarding and exit.
What the implementation is mapped to.
The FATF Recommendations remain the global benchmark and mandate a risk-based approach. Recommendation 16 — the Travel Rule — was revised in June 2025 to address fraud and proliferation financing explicitly. Implementations are also built against national regimes such as the US Bank Secrecy Act and the EU AML framework, as applicable to your licence.
How many alerts did your team clear last month — and how many were real?
That ratio is the health of an AML system. Tell us yours and we will tell you what is mistuned.
Contact us- info@bstedge.com
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- Tooling & integration, not legal advice