top of page
Team Brainstorming Session

Your AML Framework. Honestly Assessed.

We work with payment institutions, fintechs, and smaller financial firms preparing for the EU’s new AML framework. We do not give you a generic report. We give you an honest view of where you stand and what needs to change.

Services

AML Training

We deliver practical, senior-led training for compliance teams, boards, and first-line staff. Training is built around the obligations your firm faces under the new EU AML framework.

​

Sessions cover customer due diligence requirements, transaction monitoring governance, SAR quality and decision-making, and beneficial ownership verification.

 

Training is delivered in person or remotely and is tailored to your firm's size, risk profile, and regulatory context.

​

​

​

​

​

​

AML Governance Reviews

We sit with your compliance team and examine your framework as it operates not as it appears on paper.

 

That means reviewing your policies and controls, looking at how transaction monitoring is governed day to day, sampling client files, and identifying where the real gaps are between your current framework and what a regulator would expect to find.

​

You get a board-ready report covering where you stand today, what an inspector would find if they arrived tomorrow, and what needs to be addressed before July 2027. The findings are specific to your firm. Not a generic checklist.

​

This service is relevant to banks, payment institutions, EMIs, fintechs, CASPs, asset managers, wealth managers, and investment firms operating in the EU.

KYC Remediation

Our reviews find the gaps you already suspect. Client files that are incomplete, source of wealth documentation that has not been verified, risk ratings that no longer reflect the client profile, and ownership structures that have never been mapped.

​

We work with your team to design and oversee a structured remediation programme that addresses those gaps.  That means setting the prioritisation criteria, establishing a methodology, and producing the documented audit trail that demonstrates to a regulator that you identified the problem and dealt with it properly.

​

Remediation is available as a standalone engagement or as a follow-on to an AML governance review.

​

​

​

​

SAR Review

Suspicious activity reporting is one of the most consistent inspection failure points across firms of all sizes. Defensive filing, inconsistent decisions across similar fact patterns, SARs with no meaningful analysis, and no documented rationale for alerts closed without a filing. Inspectors find it quickly and treat it seriously.

​

We review your SAR decision-making process end to end. That means examining your escalation process, the quality of analysis in your filings, the consistency of decisions across cases, and your documentation of non-filing rationale.

​

You get a clear picture of where your SAR process holds up and where it does not, with specific recommendations your team can act on.

​

​

​

​

Pre Inspection

A supervisory visit is not the moment to find out where your gaps are. By the time an inspector is sitting across the table from your compliance team, it is too late to fix what they are about to find.

​

A pre-inspection readiness review is a focused, time-limited engagement designed to give you an honest view of what a regulator would find if they arrived today. We look at the areas inspectors focus on, transaction monitoring governance, client acceptance decisions, SAR quality, and beneficial ownership verification, and give you a picture of what needs attention before the visit.

 

This is not a full governance review. It is a targeted sense check for firms that believe they are broadly compliant but want an experienced, independent view before a regulator provides their own.

How it Works?

01

We Review Your Framework

We work directly with your compliance team. We examine your policies, controls, and client files as they actually operate, not as they appear on paper. No templates. No assumptions.

02

You get a clear, honest assessment of your gaps. What an inspector would find today. What needs to change before July 2027. Named, specific, and prioritised.

We Tell You Where You Stand

03

You walk away with a board-ready report and a clear path forward. If you need support implementing the findings or an independent view. We are there for both.

You Fix It With Confidence

European_Union_main_map-1.svg.png

Why choose us?

Founder AML EU AMLA .png

20 Years Inside Tier 1 Banks

Not theory. Not a framework exercise. The experience behind every review comes from two decades working inside Deutsche Bank, BNP Paribas, and Morgan Stanley.

We do not write generic reports.

Every finding is specific to what we see in your controls.. You get a clear picture of where you stand and what needs to change, not a template with your name on it.

Built for Smaller Firms

Large consultancies are built for large clients. Claritas Risk is built for firms that need precise, senior-level input without the overhead of a firm that bills by the team.

Senior-Led. Every Time.

Your review is led by Everett Morgan directly. Not passed to a junior team. Not managed from a distance. You get senior expertise applied to your specific firm.

Inspection Experience From the Inside

Everett has sat with compliance teams as they face regulators. He knows how inspections unfold in practice, what examiners focus on, and what separates firms that hold up under scrutiny from those that do not.

Honest Findings. Always.

If your framework is in good shape, we will tell you. If it needs work, we will tell you exactly what and why. No softening. No upselling.

bottom of page