• Establishment of AML/CTF Systems including preparation of internal policies, statements, work instructions, and forms.
• Setting up a comprehensive internal control environment.
• Conducting independent assessments of established AML systems, including risk analysis, KYC procedures, customer transaction monitoring, record-keeping, and review of internal policies and processes.
• Preparing statements on risk acceptance.
• Assisting with or preparing annual risk analyses from an AML perspective.
• Preparing proposals for annual reports on compliance with AML requirements based on the Anti-Money Laundering Act
• Preparing proposals for forms for regular reporting on the effectiveness of AML systems (KPIs and standards).
• Preparing functional specifications for IT system upgrades.
• Reviewing and testing IT systems for transaction monitoring and preparing proposals for improving system efficiency.
• Conducting assessments of IT providers offering comprehensive software solutions for AML and CTF risk management.
• Preparing training materials and organizing training sessions for employees.
• Providing mentorship for the designated AML officer.
• Performing all listed functions as an external service provider.

• Independent analysis of compliance requirements tailored to your business model.
• Independent assessment of compliance functions with ISO standards.
• Independent assessment of anti-corruption policies based on ISO standards.
• Assistance and advice on meeting personal data protection requirements (GDPR).
• Assistance with implementing U.S. tax law requirements (FATCA).
• Preparation of training materials and organization of training sessions for employees.
• Preparation of materials for obtaining licenses issued by regulators (policies, work instructions, codes, guidelines, etc.) and preparation of professional presentations for official meetings with regulators/investors/clients/banks.

Ethical Business Practices:

• Preparation of a Code of Conduct.
• Establishment of a system for reporting deviations and undesirable practices.
• Raising employee awareness of company values and principles.

• Establishment of an effective fraud prevention system.
• Defining fraud indicators and early signs of fraud.
• Assessment of risk analysis and vulnerability to fraud.
• Independent assessment of the established system for effective fraud prevention.
• Preparation of training materials and organization of training sessions for employees.
• Organization of computer forensics.

• Preparation of policies and methodologies for evaluating measures proposed by internal audit.
• Preparation of an audit plan based on risk assessment.
• Performing all listed tasks as an external service provider.

• Establishment of a compliance system with restrictive measures, including the preparation of internal policies and work instructions.
• Establishment of an effective and comprehensive internal control environment.
• Independent assessment of established compliance systems with international restrictive measures.
• Assistance with and/or preparation of the company's annual risk analysis from the perspective of restrictive measures.
  Preparation of functional specifications for IT system upgrades.
• Review and testing of IT systems for checking entities and payments, and preparation of proposals for improving system efficiency.
• Assessment of IT providers offering comprehensive software solutions for managing risks related to restrictive measures.
• Preparation of training materials and organization of training sessions for employees.

• Establishment of policies for handling clients who provide virtual currency services.
• Creation of a risk assessment for the obliged entity and preparation of a methodology for calculating customer risk assessment.
• Preparation of a list of indicators related to virtual currencies.
• Preparation of scenarios for transaction monitoring and identification of suspicious activities.
• Employee training, including presentations on money laundering typologies related to virtual currencies.
• Conducting an independent review (Quality Assurance/Internal Audit) for the virtual currency business area.

When establishing systems, we prepare:

• Gap analysis (current state snapshot)
• Process review
• Preparation of policies and work instructions
• Comprehensive review of the internal control environment (ICS) based on the COSO methodology
• Audit program for subsequent system performance reviews
• Risk analysis and a model for calculating customer risk
• Process for conducting simplified, regular, and enhanced customer due diligence
• Process for careful monitoring of customer activities
• Record-keeping system
• Training materials and effective training sessions

As part of the independent assessment, we prepare:

• Gap analysis (current state snapshot)
• Three levels of solutions with an approximate estimate of additional investments needed for implementation. Each proposal (measure) is evaluated based on priority, proportional to the risk posed by the identified deviation, and the resources needed for successful implementation of recommendations.
• Action plan based on your capabilities, along with necessary resources and timeline.

If you do not have your own resources to carry out the activities listed under "areas of operation," we can be your partner in:

• Providing partial or complete support in the implementation of recommendations.
• Monitoring the implementation of activities in accordance with the action plan.
• Addressing deficiencies identified by the regulator.
• Performing services for you (outsourcing partner).