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Financial Crime Controls for Unregulated Lenders Evidence & Implementation Kit

$249.00
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Financial Crime Controls for Unregulated Lenders and Shadow Banking · assess your risk, make structure transparent, do CDD, monitor and report, get the perimeter right, prove it works
Build an AML and CFT programme calibrated to your own risk, not one inherited from a parent group.
Every control handed to you adopt-ready, from a business-model risk assessment written for your own entity through transparent SPV and beneficial ownership mapping, risk-based customer due diligence and onboarding, transaction monitoring with a suspicious activity reporting process that respects the tipping-off rules, a confirmed registration and regulatory perimeter, and an independent audit that proves the controls work.
Ready in a weekend, not a quarter.

Here is the honest situation. Here is the honest situation. Financial crime obligations do not stop at the edge of the regulated sector. The FATF risk-based approach, the UK Money Laundering Regulations 2017 and the US Bank Secrecy Act all reach unregulated lenders, safe custody providers, money brokers, financial leasing companies and fintech platforms that run money through SPV structures, and many of those firms still assume that because they are not authorised by the FCA they are outside the regime. They are not. An unregulated lender or an Annex 1 financial institution registers its AML supervision with the FCA, a money services business registers with HMRC in the UK or FinCEN in the US, and a suspicious activity report still goes to the National Crime Agency with all the tipping-off exposure that carries. Borrowing a parent group's compliance manual does not close that gap, it hides it, because the manual was calibrated to a different business model and a different risk.

This Kit removes the guesswork. It is financial crime controls for unregulated lenders and shadow banking written as adopt-ready controls, so your own business-model risk is assessed honestly, SPV and beneficial ownership are made transparent, customers are onboarded with due diligence proportionate to risk, transactions are monitored and genuine suspicion is reported correctly, your registration and regulatory perimeter is confirmed rather than assumed, and an independent audit shows the whole programme actually works.

What you get, the moment you buy

18
Controls, adopt-ready. Every control, written so you personalize and apply it.
18
Evidence-they-examine checklists. For each control, exactly what a reviewer examines, plus where teams fall short, so you close the gap first.
1
Control Matrix, pre-built. Every control in a working spreadsheet, ready to record status, owner and evidence location.
1
Gap & Readiness Assessment. Score each control and the workbook returns your readiness as a single percentage, and exactly what to fix next.

Grounded in real AML and CFT practice, including the FATF risk-based approach and 40 Recommendations, the UK Money Laundering Regulations 2017 with FCA and HMRC supervision and Annex 1 registration, the suspicious activity reporting regime to the National Crime Agency and the tipping-off offence, US Bank Secrecy Act obligations with FinCEN and money services business registration, beneficial ownership transparency, SPV, orphan and back-to-back leasing typologies, and the independent AML audit function.

Assess your own risk, do not inherit a manual that was never yours
An unregulated lender or shadow-banking entity that runs on a parent group's AML framework carries an unmanaged supervision-and-enforcement tail, and the fix is a programme calibrated to how financial crime risk actually arrives in this business, through the SPV, the leasing chain, the money broking flow, not avoidance. This Kit builds the business-model risk assessment, the structure and SPV transparency, the customer due diligence, the monitoring and suspicious activity reporting, the registration and perimeter confirmation, and the independent audit that keep the programme honest, current and provable.

What one control looks like

This is the opening control, where the assessment begins. All 18 are built to this depth.

FINCRIME-1 Produce a standalone entity-level money laundering risk assessment BUSINESS-MODEL RISK ASSESSMENT
Put this control in place

Require [your organization name] to prepare, approve and maintain a written firm-wide money laundering, terrorist financing and proliferation financing risk assessment specific to the entity, covering its products, customer types, delivery channels, geographies and structural arrangements, reviewed at least annually and after any material change to the business model.

Control note.

If the assessment could describe any lender, it is too generic to defend under the risk-based approach.

Evidence a reviewer examines
  • The current firm-wide risk assessment document with version history and board or senior management approval date
  • Risk methodology showing how likelihood and impact scores are assigned across products, customers, channels and geographies
  • Meeting minutes recording review and approval of the risk assessment
  • Change log linking business model changes to risk assessment updates
Common finding they raise: Teams treat the risk assessment as a one-off compliance artefact and never revisit it, so it no longer reflects the products or customer base the firm actually serves.

Why this is not another template pack

  • The assessment is real. A borrowed parent-group manual proves nothing and misreads your risk. This tells you how to assess, make transparent, onboard, monitor, report, register and prove, for every control.
  • The specifics built in. The FATF risk-based approach, MLR 2017 with FCA versus HMRC supervision and Annex 1 registration, SAR filing to the NCA with tipping-off discipline, BSA and FinCEN money services business registration, beneficial ownership transparency, and SPV, orphan and back-to-back leasing typologies are written into the controls, not left generic.
  • Built on real regime practice, not one jurisdiction. The controls are principle-level, so they hold across UK, US and FATF-aligned regimes and stay useful as supervision and typologies change.

Who buys this

Unregulated lenders, safe custody providers, money brokers, financial leasing companies, and fintech platforms using SPV structures, and the compliance leads, MLROs and finance officers who own their financial crime risk.

By the end of the weekend you will have
✓  An adopt-ready control for all 18 areas
✓  A completed control matrix
✓  The evidence a supervisor and an independent AML audit examine
✓  A business-model risk assessment written for your own entity with transparent SPV and beneficial ownership mapping
✓  A risk-based customer due diligence process, a transaction monitoring and suspicious activity reporting flow with tipping-off discipline, a confirmed registration and regulatory perimeter, and an independent audit design
✓  A readiness percentage and a fix list

Common questions

Is it really editable? Yes. Word and Excel files you own and adapt. No portal, no subscription.

Does it cover the whole programme? Yes. Business-model risk assessment, structure and SPV transparency, customer due diligence and onboarding, transaction monitoring and suspicious activity reporting, registration and regulatory perimeter, and governance and control effectiveness each have their own controls with their own evidence.

Is this tied to one regulator or one country? No. The controls are principle-level, drawn from the FATF risk-based approach and mapped to the UK Money Laundering Regulations 2017 with FCA and HMRC supervision and to the US Bank Secrecy Act with FinCEN, so they apply across unregulated lenders, safe custody providers, money brokers, leasing companies and SPV-based fintech in FATF-aligned regimes.

Who is it for? Unregulated lenders, safe custody providers, money brokers, financial leasing companies and fintech platforms using SPV structures, and the MLROs and compliance leads who must own their own financial crime risk rather than inherit a parent group's.

Do not let a borrowed compliance manual you read as adequate become the gap a supervisor finds, or a missed suspicious activity report become a tipping-off exposure you cannot defend.
Every control is fast to adopt with the Kit. It is instant, and it is guaranteed.
Add it to your cart and be ready this weekend.

Instant digital download · 30-day money-back guarantee · The Art of Service Pty Ltd, GPO Box 2673, Brisbane QLD 4001 · support@theartofservice.com

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