Add-On Modules
Available alongside any tier engagement. Can also be delivered as standalone engagements for firms with an existing framework in place.
KYC / KYB Documentation Architecture
For PSP · Fintech · CASP
A structured onboarding and verification documentation framework developed with reference to commonly observed regulatory frameworks across the UK (FCA / MLR 2017), EU (AMLR / MiCA) and Switzerland (AMLA / FINMA).
Designed for firms operating internal onboarding teams or integrating third-party KYC/KYB vendors, requiring structured and defensible documentation without outsourcing the onboarding function.
This module complements existing AML frameworks and does not replace operational onboarding processes.
Areas covered:
• Onboarding Logic
Customer and corporate onboarding workflows and verification documentation
• Risk Classification
Risk scoring framework and review triggers, including escalation logic
• CASP Variant
Crypto-specific risk scoring, blockchain analytics integration logic and unhosted wallet considerations
• Standards
Documentation standards, record-keeping structure and integration with AML frameworks
Delivery
3–4 weeks from completion of the intake questionnaire
Format
Word / PDF · written delivery only
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Best paired with
Foundation (Tier 2) or Advanced (Tier 3)
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Fee
Upon request
Digital Identity & EUDI Readiness
For PSP · Fintech · CASP
A structured documentation module addressing the integration of emerging European Digital Identity (EUDI) frameworks into existing onboarding and verification architectures.
Designed for firms preparing for the transition from traditional KYC models to hybrid identity environments, combining state-issued digital identity wallets with established verification processes.
This module complements existing KYC/KYB and AML frameworks and defines how digital identity sources are incorporated into onboarding logic, without replacing core compliance responsibilities.
Areas covered:
• Digital Identity Integration Logic
Definition of how EUDI-based identity data is accepted, validated and incorporated into onboarding workflows
• Dual Onboarding Architecture
Structured design of parallel onboarding flows:
EUDI-enabled and traditional identification processes
• Data Scope & Sufficiency Rules
Assessment criteria for determining whether shared identity data meets regulatory and internal requirements
• Risk Classification Alignment
Adaptation of risk scoring frameworks to account for state-issued digital identity inputs
• Fallback & Exception Handling
Procedures for cases where EUDI is unavailable, partially used or insufficient
• Documentation & Audit Trail Standards
Record-keeping structure for documenting the use of digital identity in onboarding and verification processes
Delivery
3–4 weeks from completion of the intake questionnaire
Format
Word / PDF · written delivery only
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Best paired with
KYC / KYB Documentation Architecture
Foundation (Tier 2) or Advanced (Tier 3)
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Fee
Upon request
Annual Review & Update
Ongoing documentation maintenance · PSP · CASP
A structured annual review and update of existing AML and compliance documentation, designed to support ongoing consistency, relevance and alignment with evolving regulatory frameworks.
Particularly relevant as regulatory frameworks continue to evolve across the UK, EU and Switzerland, including developments under AMLA, AMLR and related supervisory guidance.
Areas covered:
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Documentation Review
Review of existing documentation with reference to current regulatory frameworks and industry practices
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Gap Identification
Structured identification of documentation gaps and update priorities
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Document Updates
Updated versions of selected documents requiring revision
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Change Summary
Written summary of relevant regulatory and structural developments across jurisdictions
Delivery
3–4 weeks from document submission
Format
Word / PDF · written delivery only
Frequency
Annual · recommended within 12 months of initial framework delivery
Fee
Upon request
EU · UK · Switzerland Jurisdiction Mapping
For firms operating across multiple regulatory environments
A comparative compliance documentation framework for firms operating — or expanding — across two or more jurisdictions within the UK, European Union and Switzerland.
Designed to reduce duplication, identify common structural approaches and support the development of consistent documentation across multiple regulatory environments.
Areas covered:
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Regulatory Matrix
Comparative mapping of EU (AMLR), UK (MLR 2017) and Switzerland (AMLA) frameworks, presented side by side
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Common Standard
Identification of shared structural approaches across selected jurisdictions
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Unified Framework
Documentation structured to operate across multiple environments, with jurisdiction-specific annexes where required
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Function Design
Compliance function structuring and accountability mapping for multi-jurisdictional operations
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Implementation Guidance
Prioritised action sequence and structured implementation notes
Delivery
4–5 weeks from completion of the intake questionnaire
Format
Word / PDF · written delivery only
Suitable for
PSP and CASP firms operating in two or more of: EU · UK · Switzerland
Fee
Upon request
