complyadvantage.

com

A Guide to
the Essentials
of Anti-Money
Laundering
2 A Guide to the Essentials of Anti-Money Laundering

Setting the scene

A more complex regulatory landscape – taking in
The financial services industry is experiencing a period of
an expanding list of money laundering and terrorist financing
unprecedented diversity and instability. The average bank has
threats, as well as ever-shifting sanctions lists –
9.4 active partnerships with FinTechs, according to Gartner.
places firms under greater pressure to understand their
The disruptor ecosystem continues to go from strength to
obligations. In this context, more businesses than ever need
strength, with projected performance suggesting strong
to understand the practical essentials of AML.
and sustained growth across these relatively new markets:
This includes established financial institutions (FIs), newer
from payments (over $3 trillion in revenue by 2027,
market disruptors, and non-FI firms that risk exposure
according to McKinsey) to digital banking ($31.3bn by 2033,
to money laundering through the nature of their business.
Dimension Market Research), to InsurTech ($336.5bn by
2032, Market.us).
Yet comparative AML knowledge and experience across
these businesses remains uneven. FinTechs and innovators
At the same time, firms face huge economic and geopolitical
tend to excel at delivering seamless customer experiences
uncertainty. The Russian invasion of Ukraine in 2022
but lack the deep compliance experience and disciplined
transformed the use of sanctions, with new measures
governance framework that is second nature to banks
implemented by Western governments at a historic pace.
and other traditional financial institutions. Law firms,
Financial markets also remain nervous, with major indexes
accountancy firms, trust and company service providers, and
fluctuating significantly, and venture capital funds are cautious.
real estate agents are all vulnerable to money laundering
Analysis by EY showed VC investments dropped 35 percent
threats but are often assumed to be under less regulatory
year-on-year in 2023 to their lowest level in four years.
oversight than FIs, as the Financial Action Task Force’s
This heady mix of market opportunity and volatility means (FATF) 2024 review of these ‘gatekeepers’ noted.
the reputational and financial highs and lows that come
This guide exists to help businesses of all kinds turn
with managing regulatory obligations well or badly are
compliance into a competitive advantage. It contains
more heightened today than ever. As businesses expand
actionable insights on developing compliance programs,
their customer base, they increase their likelihood of being
maintaining strong relationships with regulators, and
targeted as conduits for money laundering and other
building customer trust without sacrificing business growth.
financial crimes; major fines for compliance failures are not
uncommon for businesses in the financial system or those
with access to it. Without robust anti-money laundering and
countering the financing of terrorism (AML/CFT) measures
in place, businesses of all sizes risk exposure to financial and
reputational consequences.
 ComplyAdvantage.com 3

Contents
An introduction to compliance
AML: Breaking down the most common acronym in compliance

A risk-based approach to compliance

Know Your Customer: What is it, and why does it matter?

What is real-time sanctions screening?

What are the latest AML regulations?

United Kingdom
Europe
United States

The three pillars of a robust compliance program

How to build a compliance program:

A practical guide
1. Appoint a compliance officer

2. Conduct customer due diligence

3. Carry out ongoing monitoring

4. Choose an AML software vendor

Next steps
Getting started with ComplyAdvantage

Success stories
4 A Guide to the Essentials of Anti-Money Laundering

An introduction
to compliance
Anti-money laundering
(AML): Breaking down
the most common acronym
in compliance
Anti-money laundering (AML) is an umbrella term for the
various policies and legislation that require FIs to prevent
their customers from channeling funds derived from criminal
activity into the global financial system.

The Financial Action Task Force (FATF), an

intergovernmental body formed in 1989 by the G7 group
of advanced economies, designed most AML standards
and a framework for countries to implement. Those failing
to introduce proper legislation to combat money laundering
have their shortcomings exposed in FATF’s mutual
evaluation reports, an effective way of ensuring national
authorities update their AML policies and practices.
 ComplyAdvantage.com 5

A risk-based approach Know Your Customer

to compliance (KYC): What is it, and
Until the mid-2000s, financial institutions managed why does it matter?
compliance by applying a standardized list of requirements
to all customers. Then, in 2007, the FATF introduced To implement a risk-based approach, firms must know their
the concept of a risk-based approach to compliance. customers before they start doing business with them and
This was formalized in its 2012 update to the International throughout the lifetime of the relationship.
Standards on Combating Money Laundering and the
KYC involves collecting data on new customers, such as
Financing of Terrorism and Proliferation, otherwise known
their name, address, and the nature of their relationship
as the ‘40 Recommendations’.
with the institution, and verifying that data with appropriate
A risk-based approach involves tailoring a compliance documentation. This information is then used to assess the
program to the outcome of a business-wide risk assessment customer’s risk level as part of the customer due diligence
and the level of risk associated with each customer, ensuring (CDD) process – a concept this guide will return to.
firms can allocate resources where
Know Your Customer (KYC) and AML are sometimes
they are most needed.
used interchangeably. However, there’s a clear distinction
Some of the key considerations for a risk-based between the two terms: AML describes compliance rules,
approach include: while KYC is one of the key tools used to enforce them.

• Which financial crime typologies is an

organization most exposed to?
Know Your Business

• Is it exposed to risks owing to specific These measures also apply to business customers or
customers, products, or locations? companies in firms’ supply chains, a process referred to
as Know Your Business (KYB). KYB determines whether
• Does it understand and meet its a business is authentic or conceals its owners to facilitate
regulatory obligations? illicit activity. If a company or individual is or appears
to be acting on behalf of someone else, then institutions
• Has it set its risk appetite? should establish ultimate beneficial ownership (UBO).
For instance, criminals may set up a company in a
• Are its policies and controls reviewed regularly? low-regulation, offshore jurisdiction and use it to trade
with legitimate counterparties to circumvent AML rules.
Implementing a risk-based approach requires several
measures to ensure firms know their customers. To establish UBO, firms must obtain information about
a business customer, including its address, registration
and licensing documents, and the identities of its directors
and owners. Sources include government and global
corporate registries. Firms may also need to conduct KYC
checks on business personnel.
6 A Guide to the Essentials of Anti-Money Laundering

What is real-time
sanctions screening?
Screening prospective customers in a variety of ways is a
crucial part of any firm’s AML obligations – more on this
later. For now, it’s important to note the importance of real-
time sanctions screening, an area that has come under the
international spotlight and requires particular attention from
firms to avoid non-compliance with the various regulations
that govern it.

Firms should screen customers against global sanctions

lists to avoid facilitating sanctions evasion, a task that has
become significantly more complex in recent years because
of changes in the sanctions environment. In part, the volume
of sanctions has increased rapidly due to the war between
Russia and Ukraine. Lists of sanctioned individuals and
entities are maintained by several bodies across the world
and are liable to change at short notice.

For these reasons, it’s become more important than ever

for businesses to stay informed of sanctions updates
and conduct ongoing customer monitoring rather than
only screening them at onboarding. Access to real-time
sanctions screening, which informs firms immediately of
any changes in customer status relating to sanctions and
collects data from all relevant sources, is now an important
pillar of AML compliance. Given the complexity of sanctions
evasion methods, often involving convoluted networks of
transactions and parties, a sanctions screening solution will
ideally provide information on people and businesses linked
to sanctioned entities.
 ComplyAdvantage.com 7

What are the latest The Money Laundering, Terrorist Financing and Transfer of
Funds Act, abbreviated to Money Laundering Regulations
AML regulations? (MLR) 2017, transposed the EU’s fifth anti-money laundering
directive into UK law, while MLR 2019 implemented it.

United Kingdom To manage the transition from the EU’s sanctions regime
after Brexit, the UK introduced the Sanctions and Anti-
The Proceeds of Crime Act 2002 (POCA) is the UK’s Money Laundering Act (SAMLA) in 2018. SAMLA gives the
primary AML regulation. POCA defines offenses as UK government the power to lift and impose sanctions in
the carrying out and enabling of money laundering accordance with international obligations and as part of its
and the acquisition and distribution of the proceeds. own regime (which sets a lower bar than the EU).
The legislation states that firms should have controls
in place, such as CDD and transaction monitoring, and In 2022, the UK introduced the Economic Crime (Transparency
sets out reporting requirements. and Enforcement) Act (ECCTA), which was subsequently
amended the following year. Notably, this legislation introduced
The Terrorism Act focuses on preventing terrorism a ‘failure to prevent’ offense for cases where an organization is
financing and relies on CDD, transaction monitoring, deemed not to have reasonable measures in place to prevent
and reporting. Since its introduction in 2000, it has an individual associated with it from committing money
been amended several times, most recently in 2007. laundering, fraud, and other financial crimes.

Authorities

The Financial Conduct Authority (FCA) is the UK’s

main regulator. Its mandate is to supervise the
country’s financial system and its participants,
which includes monitoring compliance with AML
regulations and investigating money laundering
and terrorism financing offenses.

His Majesty’s Revenue and Customs (HMRC)

shares the responsibility of enforcing regulations
with the FCA. It issues guidance, such as
requirements for CDD, transaction monitoring,
and publishing an AML policy statement.

The National Crime Agency and Serious Fraud

Office also play roles in enforcing regulations.
They have the power of arrest and can seek
warrants and court orders. The Crown Prosecution
Service prosecutes cases.
8 A Guide to the Essentials of Anti-Money Laundering

Europe 5AMLD (implemented January 2020)

• Brought cryptocurrency and crypto exchanges under

The European Parliament issues periodic anti-money
the scope of the regulations and gave financial
laundering directives (AMLD), which member states must
intelligence units powers to obtain the identity of holders.
enforce as part of domestic legislation. These directives
aim to establish a consistent regulatory environment • Required providers of cryptocurrency services to register
across the region. Each AMLD comes with an implementation with financial authorities.
date and may last several years. The EU publishes new
directives regularly to address emerging threats. There are • Reduced the limit on prepaid cards from €150 to €50
six AMLDs, with each directive adding to or updating the for online transactions.
previous one. Here’s a summary of the most recent.
• Brought high-value goods like artwork under the
4AMLD (implemented June 2017) legislation for transactions above €10,000.

• Expanded the scope of regulations to previously • Made UBO registers public and interconnected lists
unregulated firms like gambling services and new across the EU to improve verification.
transactions and products, such as e-money products.
• Required firms to perform EDD on customers from
• Required firms to record UBO information in
high-risk countries.
centralized registers and added senior management
officials to the definition.
• Forced member states to publish PEP lists.

• Required firms to incorporate geographic locations,

6AMLD (implemented June 2021)
products, services, types of transactions, and delivery
channels into customer profiles. • Harmonized the definition of money laundering across
member states to close loopholes in domestic legislation.
• Made tax crimes predicate offenses and brought legal
advice under the scope of reporting requirements. • Added aiding and abetting to the list of AML offenses.

• Expanded the definition of PEPs to include domestic PEPs. • Extended criminal liability to include legal persons
(companies and partnerships) where they fail to prevent
illegal activity.

• Increased the minimum prison sentence for money

laundering to four years.

The ‘new’ 6AMLD which became law in 2024:

• Introduced regulations to create a single EU rulebook

encompassing all AML legislation.

• Established a new EU-wide regulator, the Authority for

Anti-Money Laundering and Countering the Financing
of Terrorism (AMLA).

• Extended the application of existing AML legislation to

new entities, including the virtual asset sector, football
clubs and agents, and luxury goods traders.
 ComplyAdvantage.com 9

United States
The Bank Secrecy Act 1970 is America’s primary AML Authorities
regulation. It requires firms to implement CDD and
screening measures and to report and keep records of The Financial Crimes Enforcement Network
suspicious transactions and customers. (FinCEN) is the main AML regulator in the US.
It monitors firms and individuals and analyzes
The US Patriot Act was passed in 2001 in response to suspicious transactions. FinCEN shares information
the 9/11 terrorist attacks. It targets terrorism financing, with state and national law enforcement agencies.
giving law enforcement agencies greater surveillance and
investigatory powers, introducing new screening and CDD The Office of Foreign Assets Control (OFAC)
measures, and increasing the penalties for breaching the administers and enforces sanctions designed
rules. It specifically focuses on cross-border transactions. to prevent targeted countries, regimes, and
individuals from committing crimes like money
The Anti-Money Laundering Act 2020, approved at the laundering and terrorism financing.
beginning of January 2021, introduced the biggest AML
reforms since the US Patriot Act. The act strengthens
and modernizes infrastructure to account for emerging
technologies and new criminal methods. Its measures
include stricter beneficial ownership rules, heavier
penalties, and protection for whistleblowers.

Other relevant AML regulations include:

• Money Laundering Control Act 1986

• Money Laundering Suppression Act 1994

• Money Laundering and Financial Crimes

Strategy Act 1998

• Suppression of the Financing of Terrorism

Convention Implementation Act 2002

• Intelligence Reform and Terrorism Prevention Act 2004

Breaches can result in criminal and civil penalties, fines,

and prison terms for the most serious offenses. Daily fines
start at $10,000 for not reporting foreign financial agency
transactions to $100,000 for CDD failures. Guilty parties also
suffer reputational damage and usually must forfeit assets
or funds obtained through criminal activity.
10 A Guide to the Essentials of Anti-Money Laundering

The three pillars of a robust

compliance program
Effective compliance programs rely on three pillars: paper,
people, and platforms. Here’s a summary of what firms
need from each.

Paper People
During an audit, or when the regulators visit, firms While the MLRO typically takes responsibility for
must present documentation explaining their developing policies, teams of people implement the
compliance activities, which provides a benchmark processes and procedures, and they should have the
against what they do in practice. Prospective investors right skills. The exact requirements depend on a firm’s
will also want to ensure that firms have comprehensive volume of transactions, resources, and perceived
risk mitigation policies in place. These documents levels of risk.
should take the following forms:
Customer service staff usually take care of basic CDD,
• Policies set out an organization’s compliance which is why they’re known as the first line of defense.
obligations. They provide a guide and confirm to A specialist team completes more advanced activities
regulators that an FI is aware of its responsibilities. such as EDD, monitoring and investigation, and the
Policies rarely change. ongoing maintenance of policies, processes, and
procedures. This team is the second line of defense.
• Processes describe how to meet these obligations. An audit is the third line of defense.
These change periodically.
Recruiting the right people is important. A given
• Procedures explain how to execute processes. business might consider hiring inexperienced
Procedures are like ‘How to’ guides, so they may individuals who can learn on the job, but investing
change regularly. upfront in experienced professionals is essential.

Firms should ensure staff receive ongoing training

to keep up with the evolving regulatory landscape.
Platforms Industry bodies such as the Association of Certified
Traditionally, compliance activities were conducted Anti-Money Laundering Specialists (ACAMS) and the
manually, but today, effective, scalable platforms should International Compliance Association (ICA) deliver
work alongside humans, as they’re cheaper and more strong training programs.
efficient than large teams. A sample of those employed
during CDD include:

• Customer relationship management (CRM)

systems for onboarding, managing client data,
and conducting risk assessments.

• ID&V platforms to capture ID documents

• Screening tools for sanctions lists, PEPs,

and adverse media
• Case management systems to manage
investigations
• Social Network Analysis tools to support
investigations
 ComplyAdvantage.com 11

How to build a compliance

program: A practical guide
1. Appoint a 2. Conduct customer
compliance officer due diligence
The first step in building a robust compliance program is to When onboarding new customers, firms must carry out
appoint a dedicated compliance officer, usually known as customer due diligence (CDD). CDD involves using the
a Money Laundering Reporting Officer (MLRO) or, in some customer details collected during the KYC process to
cases, a Nominated Officer. This individual is accountable screen them against various lists, such as:
for compliance and risk management externally to
regulators and internally to the board. The MLRO’s • Individuals with a track record of corruption.
main responsibility is to introduce measures to identify
suspicious activity and report it to the national authorities. • Countries or individuals subject to sanctions.

Other responsibilities include: • Individuals considered at risk of participating

in bribery or money laundering.
• The development of policies, procedures, and controls,
especially in relation to CDD • Individuals suspected of a crime.

• The oversight and conduct of risk assessments • Politically Exposed Persons (PEPs): individuals
with a high-profile political or public role.
• Maintaining records
The definition of PEPs is globally inconsistent, making
• Ensuring staff receive training them hard to identify. According to the FATF, prominent
positions include legislators, ministers, members of the
The appointment of an MLRO is important because it sets armed forces and judiciary, and senior executives at
the tone for how an entire firm tackles financial crime. The state-owned companies. This version covers domestic
individual needs to be part of the executive team and have and foreign officials as well as members of their families,
sufficient AML experience and expertise. although, again, practices vary across jurisdictions here.
In the UK, a 2024 review by the FCA clarified that firms
should treat domestic PEPs as automatically lower-risk
than foreign PEPs; meanwhile, the US does not regard
domestic officials as PEPs.
12 A Guide to the Essentials of Anti-Money Laundering

CDD will also cover core categories like: Enhanced Due Diligence
• Occupation and income or a company’s nature Customers judged to be high-risk may go through
of business and turnover. For example, a customer enhanced due diligence (EDD). EDD involves gathering
in permanent employment may only receive a additional information like:
single salary payment each month, as opposed to
numerous payments. • The customer’s background and reputation

• Location and areas of operation: Certain jurisdictions • The source of the customer’s funds or wealth
are considered higher risk than others.
• A business customer’s revenue
• Products: Some combinations might be considered
• The nature of the business relationship
higher risk, such as a student current account with
foreign exchange facilities.
• Explanations for typical transactions

• Channels: Face-to-face communication in a

Adverse media screening is a commonly used tool during
branch is generally deemed low risk, but digital
EDD. At its most basic, this involves inputting keywords
channels are becoming more popular, especially
into a search engine, but the results aren’t always reliable.
since the pandemic.
Once again, technology offers a solution. Natural language
processing can identify, categorize, and link people,
• Transactions: A large volume of cash transactions
businesses, and risks. This ensures compliance analysts
or cross-border traffic to high-risk jurisdictions
get a complete view of the person or entity they are
requires extra scrutiny.
reviewing and, in some cases, can identify potential red
Based on this information, firms can classify customers flags that may lead to a further investigation before alerts
as high, medium, or lower risk and assign them a more are triggered in a transaction monitoring system.
granular score to group them into subgroups within
each category. A customer risk score indicates how likely Automating the onboarding process
they are to participate in corruption or crime. This rating
Automated onboarding doesn’t just help firms meet their
provides a baseline for future behavior, such as the volume,
compliance obligations. It also removes friction from the
value, and frequency of payments, and allows firms to flag
customer journey. Here are the benefits:
irregularities and report suspicious activity. Firms can also
compare a customer’s profile with peers, as two individuals
• Compliance performance: Customer verification is
with similar occupations and backgrounds generally
costly and time-consuming when performed manually.
demonstrate comparable account activity.
Automated solutions accelerate the process and make
it more efficient because they can handle a larger
volume of data. They also improve accuracy and
remove the risk of human error.

• Automated solutions with a full audit trail help firms

store data more efficiently and accurately so they
can easily access it for reports or investigations by
financial authorities. They also consolidate data, giving
all departments access to the information and allowing
them to expedite AML alerts and send reports on time.
 ComplyAdvantage.com 13

3. Carry out
ongoing monitoring
CDD doesn’t just happen during onboarding; it should be
ongoing throughout the lifetime of the customer relationship
so firms can continually revise customer risk ratings.

The primary goal of ongoing monitoring is to ensure

nothing changes about the customer’s identity, who they
trade with and what kind of business they do. That requires
three activities:

• Transaction screening monitors overseas

transactions to determine if customers are sending
money to counterparties on sanctions or other lists.

• Customer monitoring confirms existing customers

don’t appear on updated sanctions lists, adverse
media screening databases, or other watchlists.

• Transaction monitoring checks whether client behavior

aligns with expectations formed during onboarding.

Automating these activities makes them quicker and

more accurate. However, while transaction screening and
customer monitoring can leverage the same tools used
during onboarding, transaction monitoring requires setting
rules to flag any suspicious behavior.

When a transaction pattern matches a scenario, monitoring

platforms issue an alert that must be reviewed manually.
Most analyze transactions retrospectively, leading to high
rates of ‘false positives’ after the suspicious money has
moved on from an account. However, more innovative
platforms combine industry-specific rules with scenarios
developed in-house, which teams can quickly reconfigure
using soft coding. They allow for real-time monitoring and
enrich alerts with additional data, providing a rounded view
of the customer.

TM platforms also leverage application programming

interfaces (APIs), allowing two systems to communicate.
APIs facilitate integration with existing systems, presenting
a consistent view of customers across different platforms.
14 A Guide to the Essentials of Anti-Money Laundering

4. Choose an AML False positives

software vendor ‘False positives’ drain resources, but solutions with these
features minimize them:

When selecting a vendor, firms need to consider • To deliver more specific responses, the solution
several factors: should be configurable to the risk profiles of customers,
transactions, and sectors.
Compliance requirements
• Profile-based screening allows businesses to tailor
The vendor must meet a firm’s specific requirements
measures for high and low-risk customers.
based on their customers and business environment.
Its functionality should encompass CDD, transaction • The solution should be user-friendly and accessible
monitoring, screening of sanctions lists and PEPs, and to compliance teams.
adverse media monitoring. Other considerations include:
• The solution should be flexible enough to screen for
• Data coverage: The solution should capture the relevant data attributes while ignoring irrelevant variables.
spectrum of data that firms need to satisfy their
compliance obligations.
APIs
• Speed of updates: The software should update A software solution’s application programming interface
rapidly to reflect new risk levels. (API) determines the user experience and, therefore, the
effectiveness of a firm’s compliance efforts. Firms should
• Matching algorithms: Search algorithms should take into account the following features:
identify and assess risks effectively, using tools like
‘name transliteration,’ which considers language • Integration: The API should seamlessly sync with
differences, misspellings, and aliases. existing AML systems.

• Proactive monitoring: The solution should quickly • Availability: The API should make data available
alert the compliance team when a customer’s risk accurately and timely.
profile changes.
• Security and capacity: The API should meet
industry-level security standards and handle the
capacity of search volumes.
 ComplyAdvantage.com 15

Artificial intelligence • Detecting new or emerging typologies of financial

crime, using graph-based pattern recognition to trace
The rapid development of artificial intelligence (AI) suspicious behavior within the intricate network of
applications using the vast datasets available to many financial transactions.
organizations is having a transformational impact, and the
field of AML compliance is no exception. The expanding • Improve analyst efficiency by helping teams
range of AML threats organizations must contend with, prioritize the highest-risk alerts that are most likely
as well as the data collection and analysis that effective to be true positives.
AML compliance demands, have phased out manual-only
compliance processes and made the use of AI essential.
Human expertise
However, using AI alone is not a simple solution to all firms’ The solution should complement the skills of a compliance
compliance challenges. AI is an umbrella term referring to a team. In practice, that means assessing their strengths and
number of technologies that perform functions traditionally weaknesses to guide a firm’s search for the right option.
associated with human intelligence. Generative AI, large
language models, and natural language processing are
Software deployment
all distinct examples of AI, and they all have very different
implications in an AML context. Some solutions are installed on-site, while others are hosted
in the cloud. On-site solutions offer a greater degree of
Firms must be able to understand and interrogate vendors’ control over infrastructure, which means more regulatory
claims around their use of AI, decide which technologies exposure. They also require longer implementation periods,
best suit their needs, and recognize that the success of any incur higher costs, and may need the support of an in-house
AI tool depends on: IT department.

• Data: AI tools are only as good as the quality of their When infrastructure is hosted in the cloud, businesses
underlying data. This means firms must have access to have less direct control but face lower regulatory exposure
accurate, complete, up-to-date, and relevant data. because the vendor manages maintenance and security.
Cloud solutions can also be scaled up and down depending
• Explainability: Firms must be able to explain to on demand and can be deployed rapidly.
regulators how their technology works and why every
decision they have made was taken.
Security
• Effectiveness: The success of an AI tool is ultimately A solution must protect against cyber threats and comply
measured by how well it enables compliance officers with privacy regulations consistent with the sensitivity of the
to focus on specialized tasks and high-risk cases by data collected for compliance. It should help firms achieve
automating repetitive work and carrying out intelligent ISO27001 certification. ISO27001 is a globally recognized
risk scoring. standard of information security management and includes
both technological controls, the priority for AML solutions,
ComplyAdvantage’s software uses AI for AML compliance
and physical controls. Finally, the vendor should have
in specific ways, including:
disaster recovery and business continuity strategies in place
to avoid downtime in unforeseen circumstances.
• Continuously monitoring information sources,
refreshing data automatically in near real-time rather
than relying on manual updates.

• Implementing intuitive screening and reducing false

positives by using machine learning to train screening
tools to recognize name variants, aliases, non-Latin
names and scripts, and duplicated data.

• Consolidating customer profiles so that any red flags

relating to sanctions, adverse media, PEP status, or
enforcement data appear in one place.
16 A Guide to the Essentials of Anti-Money Laundering

Next steps
Firms around the world rely on ComplyAdvantage for
360-degree AML risk detection. Firms can start using
ComplyAdvantage’s software in different ways, each
designed for specific business profiles.

ComplyLaunch is a program giving startups who haven’t

partnered with us before the chance to use our market-leading
AML software for free, allowing them to balance growth with
compliance obligations while keeping costs under control.
We also allow firms to buy small volumes of our PEP, sanctions,
watchlist, and adverse media databases online to quickly and
directly meet customer screening requirements.

Getting started with

ComplyAdvantage

ComplyLaunch Starter Plan

For early-stage FinTechs For any business with AML obligations

Free access for 12 months From $99

24/7 automatic risk monitoring Monitor up to 1000 customers

API-based integration with ongoing support API-based integration with ongoing support

Access to award-winning data Access to award-winning data

Apply now Buy now

All versions of ComplyAdvantage’s software have been

created to help businesses:

• Protect against the risk of financial crime • Boost customer satisfaction with
using a best-in-class database that updates frictionless experiences.
in near real-time.
• Scale operations with international standard
• Automate manual, labor-intensive processes. data security.

If your needs are more bespoke, our expert team is on hand to discuss them with you.
You can book a meeting with one of them here.
 ComplyAdvantage.com 17

Success stories
Holvi Freetrade
Holvi offers business bank accounts for small businesses, An investment company aiming to help everyone
sole traders, and freelancers. Facing high rates of invest simply and affordably, Freetrade partners with
payment recall, police requests, and seizures, Holvi looked ComplyAdvantage to conduct ongoing customer screening.
to AI-driven solutions to improve efficiency and accuracy
in flagging high-risk customers without disrupting Before working with ComplyAdvantage, Freetrade only
legitimate users. screened customers at the beginning of the business
relationship. The company realized it needed to implement
Holvi uses ComplyAdvantage to screen its customers ongoing monitoring as well, at the same time navigating
against adverse media, sanctions, and politically exposed both a global expansion and an increase in the complexity of
persons (PEP) lists. It also uses ComplyAdvantage’s the sanctions environment due to global events like Russia’s
transaction screening, monitoring, and fraud detection invasion of Ukraine.
products and deploys AI-driven Smart Alerts to optimize
the efficiency of its transaction monitoring. Freetrade selected ComplyAdvantage to deliver ongoing
screening and monitoring alongside the flexibility to
As Valentina Butera, Head of AML and AFC Operations, put configure the lists it screened against. Throughout the
it, “The implementation of Smart Alerts was the smoothest process, ComplyAdvantage has provided flexible screening
implementation of tech that we have ever experienced. tailored to its risks, reliable, up-to-date global sanctions, and
We did not experience downtime or interruption of politically exposed person (PEP) data, meaning Freetrade has
business operations – not even for a second. We know we seen an approximate 50% reduction in false positive alerts.
can serve our legitimate customers while at the same time
keeping a solid risk-based approach.” “The quality of data we get through ComplyAdvantage
is really important to us,” says Rob O’Sullivan, Director,
Read more Financial Crime Compliance and MLRO. “Through
ComplyAdvantage, we have comfort that we’re screening and
identifying high-level PEPs and down to local councilors.”

Read more
18 A Guide to the Essentials of Anti-Money Laundering

RealPage
RealPage provides software and data analytics to the
real estate industry, including tenant screening, online
billing and payments, accounting, revenue management,
and expenditure management. Processing around 100m
transactions per year across the US, RealPage has an
obligation to its banking partners, clients, and residents
to monitor transactions processed through its payment
services and to identify and reduce instances of fraud and
other illicit activities. Their task is made more complicated
by a growing spectrum of fraud typologies and their atypical
business model involving B2B and B2B2C relationships.

After an internal ‘buy vs. build’ debate, RealPage partnered

with ComplyAdvantage, partly because of its experience
with transaction monitoring and fraud detection beyond
traditional FIs. During implementation, RealPage met with
ComplyAdvantage to explore how to implement its unique
rule set. Once live, both teams tuned the logic of their rules,
simplifying the number of data points screened. Quarterly
success meetings provide RealPage with reporting on how
its scenarios are performing, providing an external set of
checks and balances on internal tests.

For Blanca Rojas, Transaction Risk Manager, the biggest

benefit of the ComplyAdvantage transaction monitoring and
fraud detection platform is its near real-time capabilities.
“I am seeing the activity in close to real-time – seconds. I
have worked with different software providers at different
institutions, and the rapid response to alerts is the biggest
benefit I have seen.”

Read more
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About ComplyAdvantage
ComplyAdvantage is the financial industry’s leading source of AI-driven financial crime risk data and detection
technology. ComplyAdvantage’s mission is to neutralize the risk of money laundering, terrorist financing, corruption,
and other financial crime. More than 1200 enterprises in over 80 countries rely on ComplyAdvantage to understand the
risk of who they’re doing business with through the world’s only global, real-time database of people and companies.
The company actively identifies tens of thousands of risk events from millions of structured and unstructured data points
every single day. ComplyAdvantage has four global hubs located in New York, London, Singapore and Cluj-Napoca and is
backed by Andreessen Horowitz, Goldman Sachs, Ontario Teachers’, Index Ventures and Balderton Capital. Learn more at:

complyadvantage.com

Trusted by businesses around the world

 complyadvantage.com

Disclaimer: This is for general information only. The information presented does not constitute legal advice. ComplyAdvantage accepts no responsibility
for any information contained herein and disclaims and excludes any liability in respect of the contents or for action taken based on this information.