AML Compliance Outsourcing for EU-Regulated Firms

Handle the AML workload,
stay compliant.
Scale without the overhead.

We provide outsourced KYC/ODD teams, compliance officer support and independent AML audit to EMIs, payment institutions and fintechs. All specialists EU-based, operational in two weeks.

ACAMS-certified team leads
EU data residency
KYC/ODD teams live from 2 weeks
NCA-accepted outsourcing structures
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2 weeks
KYC/ODD team from engagement confirmation to first case
EU-based
All analysts in CET/EET time zones, data stays in EU
EU-wide
Regulatory framework applies across every EU jurisdiction, we operate in all of them
0
Placement fees: fixed monthly rate model
Who We Work With

Built for regulated
financial institutions across the EU

💳

Electronic Money Institutions

EMIs carry full AML obligations under AMLD6 and face direct NCA supervision. We provide KYC/ODD teams and compliance officer support to the standard your regulator expects.

AMLD6 · EBA Guidelines · NCA supervision
🏦

Payment Institutions & Neobanks

High transaction volumes require scalable, accurate KYC and ongoing monitoring. Our teams handle CDD, EDD, PEP and sanctions screening at the volume and quality your licence demands.

PSD2 · AMLD · Ongoing monitoring
💰

Fintech Lenders & BNPL

Consumer credit AML obligations are growing. We help lending fintechs build KYC infrastructure that satisfies AML requirements and credit risk appetite without duplicating work.

CCA · AML · Responsible lending

Crypto CASPs under MiCA

MiCA requires CASPs to demonstrate full AML substance, not just policy documents. We provide compliance officer support, KYC team support and the crypto-specific AML expertise MiCA demands.

MiCA · AMLD · TFR · FATF
🌍

Non-EU Companies Entering Europe

US, UK, and APAC companies launching EU-licensed entities need AML infrastructure quickly. We handle the team, the compliance officer role, and the programme, from licence application through to live operation.

EU market entry · Substance · AMLD
⚙️

RegTech & B2B Compliance Platforms

If you build compliance tools for regulated clients, we provide the AML expertise your product needs: advisory, audit validation, independent review or analyst teams embedded alongside your technology.

Product compliance · AML validation
📊

Regulated Investment Funds

AIFMs and larger regulated funds in Luxembourg, the Netherlands and Ireland carry the same AMLD6 AML obligations as fintechs, under CSSF, AFM and CBI supervision. We provide KYC/ODD teams, compliance officer support and AML programme advisory calibrated to fund-specific customer typologies and NCA expectations.

AIFMD · AMLD6 · CSSF · AFM · CBI
🏛️

Wealth Managers & Private Banks

High-net-worth and ultra-high-net-worth customer onboarding carries disproportionate KYC complexity: beneficial ownership through multi-layered structures, PEP exposure, and source of wealth documentation. We provide ODD teams and AML programme support built for the depth of review this client base demands.

AMLD6 · PEP · EDD · Complex ownership
🛡️

Insurance Firms

Life and health insurers sit at the intersection of two regulatory obligations: AMLD applies to life insurance products, and AI pricing models fall directly under EU AI Act Annex III. We provide AML programme support, KYC teams for high-risk policy onboarding, and AI Act advisory for underwriting models.

AMLD · EU AI Act Annex III · Life insurance · EIOPA
What We Do

Everything covered.
One specialist team.

Every engagement starts with understanding your regulatory obligations, your current AML infrastructure, and where the gaps are. We scope before we propose.

S2: Outsourcing

Compliance Officer Support

Interim, fractional and licence-stage compliance officer provision. Licence applications, gap cover after departure, Deputy compliance officer resilience. ACAMS-certified, 5+ years regulated-sector experience.

  • Licence-stage provision for NCA pre-authorisation review
  • Interim gap cover: in post within two weeks
  • Board and senior management reporting
  • NCA examination preparation and attendance
Compliance Officer Support →
S3: Advisory

AML Audit and Advisory

Independent AML effectiveness audit, pre-NCA examination health check, and programme design for regulated firms building or overhauling their AML framework. Fixed fee per engagement.

  • Independent AML effectiveness audit
  • Pre-NCA examination health check
  • AML gap assessment and programme design
  • Policy and procedure documentation
AML Audit and Advisory →
S4: Crypto AML

MiCA / CASP AML Compliance

AML programme build and compliance team for crypto asset service providers under MiCA. KYC/ODD teams for crypto onboarding, Travel Rule implementation and pre-registration NCA preparation.

  • MiCA AML programme build for NCA pre-registration
  • KYC team for crypto customer onboarding and EDD
  • Travel Rule implementation and VASP screening
  • AMLCO support and deputy compliance officer
MiCA / CASP AML →
S5: Regulatory

AI Compliance for Regulated Firms

For regulated financial institutions using AI in credit decisions, insurance pricing or HR screening. Risk classification, conformity assessment and cross-regulatory advisory integrated with your AML and GDPR framework.

  • AI system classification: provider vs. deployer
  • Annex III scope and obligations assessment
  • Cross-regulatory integration with AML, GDPR, DORA
  • Written opinion and governance documentation
AI Compliance →
S1 · Outsourcing

KYC and ODD teams,
EU-based and operational
in two weeks.

We provide outsourced KYC analysts and ODD investigators who work inside your systems, under your AML policies, and report to your MLRO. The team is not a separate vendor relationship. They are your compliance function, staffed by us.

Three engagement models cover most situations: a dedicated team for ongoing volume, a capacity block for inspection prep and backlog clearance, and a case-based model for variable demand. All include ACAMS-certified team lead supervision and weekly QA reporting.

  • Customer due diligence, EDD, PEP and sanctions screening
  • Periodic ODD reviews and transaction monitoring triage
  • Three engagement models: dedicated, capacity block, case-based
  • 30-day scale-down from any point, no penalties
  • NCA-accepted structure under EBA/GL/2021/05
Full KYC / ODD Outsourcing page →
Case result
6x
Reduction in regulatory fines at a top-5 Lithuanian EMI after deploying a dedicated ACAMS-supervised team ahead of a Bank of Lithuania audit.

"They deployed four analysts within ten days. The NCA found no material issues with our KYC function."

Head of Compliance, EMI, Lithuania
View KYC / ODD service →
What we provide
Interim.
Fractional.
Licence-stage.
Three situations where external provision is the right answer: before a permanent hire is warranted, after a departure, or at licence-application stage.

Licence application: named compliance officer for NCA pre-authorisation
Gap cover: in post within 2 weeks of compliance officer departure
Fractional: defined days per month, full accountability
Pan-EU: CBI, MFSA, CySEC, Bank of Lithuania, DNB, and more
View Compliance Officer service →
S2 · Outsourcing

Compliance officer support
for the moments when
in-house is not the answer.

There are specific moments when an in-house compliance officer is either not yet warranted, temporarily unavailable, or structurally impractical. We provide the qualified, accountable senior compliance officer for those moments, without requiring a permanent hire.

ACAMS-certified, minimum five years in regulated institutions under NCA supervision. Genuine statutory accountability. Not an advisor countersigning documents from a distance.

  • Licence application: named compliance officer in post before the NCA authorisation review
  • Interim cover: in post within two weeks of a compliance officer departure
  • Fractional: defined days per month, SAR review, board reporting, NCA correspondence
  • Deputy compliance officer resilience for firms with an in-house primary
  • AMLCO support for CASP registration and ongoing compliance function
Full Compliance Officer Support page →
S3 · Advisory

Independent AML audit
and programme advisory
for EU-regulated firms.

Two services. An independent AML effectiveness audit, conducted against AMLD6 and EBA guidelines, with written findings your board can act on and your NCA can inspect. And AML programme design for firms building a framework from scratch or overhauling one that no longer meets current requirements.

Both are fixed-fee engagements, scoped and agreed in writing before any work begins. The audit output is structured for board presentation and NCA examination use. Programme deliverables include a full policy suite, BWRA and implementation roadmap.

  • AML effectiveness audit against AMLD6 and EBA guidelines
  • Pre-NCA examination health check and backlog assessment
  • Gap assessment and programme design
  • Full policy suite: CDD, EDD, PEP, sanctions, TM, SAR
  • MiCA CASP AML programme builds covered
Full AML Audit and Advisory page →
Indicative fee range
€5k–20k
AML audit or programme design. Fixed fee agreed before engagement starts. No variations without written agreement.

Prohibition audit: immediate obligations under Article 5 and Article 4
AML effectiveness audit: €6,000 to €20,000
Programme design: €5,000 to €18,000
Board presentation available on request
View AML Audit service →
MiCA: what CASPs need
Designated AMLCO with full statutory accountability
KYC/ODD for crypto customer onboarding
Travel Rule protocol implementation
Unhosted wallet attribution procedures
AML programme for NCA pre-registration review
On-chain transaction monitoring integration

MFSA · CySEC · Central Bank of Ireland · BaFin · Bank of Lithuania · Finantsinspektsioon

View MiCA / CASP service →
S4 · Crypto AML

AML compliance for CASPs
under MiCA: outsourced teams
and programme support.

MiCA is now in force. EU-licensed CASPs need a designated AMLCO, a functioning KYC/ODD programme built for crypto customer typologies, Travel Rule compliance, and an AML programme that satisfies NCA pre-registration review. Generic AML outsourcing does not cover these requirements.

Our MiCA team understands unhosted wallet attribution, blockchain analytics tool integration, on-chain transaction monitoring and the specific Travel Rule protocol mechanics required for CASP compliance. We have supported CASP programme builds for MFSA, CySEC and Central Bank of Ireland registrations.

  • AMLCO support and compliance officer provision for CASPs
  • Crypto-specialised KYC/ODD team for onboarding
  • Travel Rule: protocol selection, counterparty VASP screening
  • MiCA AML programme build for NCA pre-registration
  • Ongoing support post-registration as your CASP scales
Full MiCA / CASP AML page →
S5 · AI Compliance

AI compliance for regulated firms:
obligations that sit on the
same desk as your AML.

For regulated financial institutions, the EU AI Act is not a separate technology problem. Credit scoring, insurance pricing and HR screening AI falls directly under Annex III. The compliance function that manages your AML framework is the same function facing these obligations. They arrive at the same time and interact with the same regulatory stack.

We determine your obligations as a provider or deployer, classify your AI systems against Annex III, and produce the documentation your firm needs: written classification opinions, FRIA under Article 27, cross-regulatory mapping with your AML and GDPR frameworks. Not generic templates. Senior advisor assigned within one business day.

  • Written classification opinion per AI system (provider vs. deployer)
  • Annex III scope determination with regulatory citations
  • Fundamental Rights Impact Assessment (FRIA) under Article 27
  • Cross-regulatory integration: AML, GDPR, DORA, MiCA
  • Annex III enforcement deadline: August 2026
Full AI Compliance page →
Penalty exposure
€35M
Maximum fine under EU AI Act Article 99, or 7% of global annual turnover. Annex III enforcement: August 2026.

"The classification opinion, gap analysis and interim governance framework were delivered in three weeks. The diligence process completed without an AI Act condition."

CEO, Fintech Lending Platform, Amsterdam
View AI Compliance service →
EU Regulatory Framework

AML outsourcing is explicitly permitted
across all EU member states.
The question is whether it is done correctly.

AMLD6 and EBA/GL/2021/05 permit regulated entities to outsource their AML and KYC functions. No EU NCA can prohibit it. They can only require appropriate governance. That governance is what our team builds into every engagement from day one.

Written outsourcing agreement and DPA

A documented contract covering obligations, service levels, data handling and audit rights. Our team provides a GDPR Art. 28-compliant DPA and outsourcing agreement before any work begins.

Accountability retained by the regulated entity

Your MLRO retains accountability. Our team executes under your policies and your oversight structure. Regulators are satisfied by this arrangement when it is properly documented.

EU data residency and documented quality oversight

All analysts are EU-based. All data stays within the EU. We provide weekly QA reports and monthly performance reviews, all documented and available for NCA examination.

NCA experience across 10+ jurisdictions DNB (Netherlands) MFSA (Malta) Bank of Lithuania CySEC (Cyprus) Central Bank of Ireland Finantsinspektsioon (EE) KNF (Poland) FCMC (Latvia) · FCA · AMF · BaFin · and more
Client Testimony

What compliance teams say
about working with us

"

We were under pressure from the MFSA ahead of our annual AML review. Our KYC backlog had grown to a point where our existing team could not clear it. Four analysts were deployed within ten days, integrated into our systems, and followed our procedures exactly. The backlog was cleared two weeks before the review date. The MFSA found no material issues with our KYC function.

Head of Compliance, EMI, Malta
"

We brought them in when our customer onboarding volumes doubled in three months and our internal KYC team simply could not keep pace. Two analysts were operational within two weeks. The handover was clean, the quality was consistent from day one, and they managed themselves and reported to us weekly. Exactly what we needed.

MLRO, Payment Institution, Denmark
"

As a Cyprus-licensed PI we needed a KYC/ODD team that understood CySEC expectations and AMLD6 requirements simultaneously. They delivered both. The team handles our ongoing EDD reviews and high-risk customer monitoring. The cost compared to expanding our internal team is significantly lower, and the regulatory quality is higher than what we had before.

Head of Operations, Payment Institution, Cyprus
"

We compared three outsourcing providers before choosing this team. What decided it was the onboarding process: our AML policies were reviewed, the right questions were asked about our customer base, and the team arrived already calibrated to our risk appetite. Six months in, ODD output quality matches what our best in-house analyst produces.

Chief Compliance Officer, EMI, Lithuania
About Scanlex

A small, specialist team.
Not a compliance body shop.

We are a focused AML compliance firm: not a large agency placing CV-matched candidates, not a generalist consultancy adding AML to a long service list. Our work is exclusively in AML, KYC and financial crime compliance for EU-regulated financial institutions.

Our team leads hold ACAMS certification and bring a minimum of five years in hands-on regulated-sector compliance roles inside EMIs, payment institutions and licensed fintechs under active NCA supervision. Not generalists learning your regulation. Specialists who have run the function you need to run.

We run small, dedicated teams per client. You will not be passed between junior staff. Senior oversight on every engagement, from day one through to ongoing delivery.

Credentials
🏅
ACAMS Certification: All Team Leads
Certified Anti-Money Laundering Specialist. The global professional standard for AML compliance practitioners.
🏛️
EU-Incorporated, EU-Operated
Holding structures across several EU member states for full jurisdictional compliance. Data and operations entirely within the EU.
📋
EBA/GL/2021/05 Aligned
All outsourcing arrangements structured to EBA guidelines. Documented, supervisable and audit-ready for NCA examination.
5+
Years regulated-sector experience per lead
10+
EU NCAs we have prepared clients for
EU
All analysts and data within the EU
Why our team

Four reasons EU-regulated firms
choose to work with us

Speed to compliance

Building an in-house AML team takes 3 to 6 months. Our teams are operational in two weeks, against the same regulatory clock your NCA is watching.

💶

Predictable cost

Monthly fixed rates with no recruitment fees, no employer costs, no redundancy risk. Budget certainty at the exact moment your compliance spend is under scrutiny.

🎯

Regulatory expertise

Your analysts and compliance officer have operated in regulated environments, under real supervisory pressure. Not generalists learning on the job at your expense.

📈

Scales as you grow

Add analysts as your customer volume grows. Scale down in 30 days if you need to. No headcount commitments and no awkward conversations about compliance staffing.

ACAMS-certified team leads · EU-incorporated · 5+ years regulated-sector experience per lead

In the Age of AI

AI handles volume.
Qualified specialists
handle judgment.

AI tools can accelerate screening, flag anomalies and automate document extraction. What they cannot do is make the judgment call that decides whether a transaction pattern is suspicious, whether a corporate structure conceals a PEP, or whether your AML programme will hold up in front of an NCA examiner.

Regulators do not accept an algorithm as your MLRO. An NCA examiner will ask who reviewed the SAR, who briefed the board, who maintains accountability for the programme. That answer has to be a qualified person with a name and credentials.

We provide that person, and the team around them. ACAMS-certified leads, 5+ years each in regulated institutions under active supervisory pressure. Not AI-assisted generalists, but specialists whose career has been built on the compliance function you need to run.

🏛️
NCA examiners look for humans

Regulatory examination requires named, accountable individuals. An AI tool has no regulatory standing. The MLRO, the case reviewer, the SAR signatory must be a qualified person.

⚖️
Judgment cannot be automated

CDD and EDD require contextual reasoning: is this source of funds plausible? Does this ownership structure make commercial sense? These are not threshold questions. They require expertise.

📋
Regulators require documented reasoning

Every material compliance decision must have documented human reasoning behind it. An AI flag is not a decision. The analyst who assessed it and the senior who reviewed it are what the audit trail requires.

🎯
We are the solution, not the tool

We provide the qualified specialists who operate alongside whatever technology your firm uses. Our team works inside your systems, applies your policies, and carries the regulatory accountability that no AI product can bear.

What AI tools do well vs. what still requires a qualified specialist
AI tools
  • Screening name lists at volume
  • Document extraction and OCR
  • Transaction pattern detection
  • Alert generation and routing
  • Risk score calculation
  • Case workflow management
Qualified specialist
  • Assessing whether a match is a true positive
  • Judging source of funds plausibility
  • Determining whether to file a SAR
  • Reviewing EDD cases end to end
  • Maintaining accountability to the NCA
  • Briefing the board and standing behind the programme

On AI-assisted KYC products: If your firm uses an AI-powered KYC tool, you still need analysts to review its output, manage the exceptions it cannot handle, and ensure the function meets the standard your regulator expects. The tool reduces volume. The specialist carries the accountability. We provide the specialist.

FAQ

Questions from
compliance teams

Can't find your answer? Contact us directly. We respond within one business day.

Is AML/KYC outsourcing accepted by EU regulators?+

Yes. Outsourcing AML and KYC functions is explicitly permitted under Article 25 of AMLD6 and EBA/GL/2021/05, uniformly across all EU member states. No NCA can prohibit it: they can only require it to be done correctly.

What regulators require is a documented outsourcing agreement, a GDPR-compliant data processing agreement, evidence of quality oversight, a clear escalation path to your MLRO, and the ability for the NCA to examine the outsourced function. Our engagement structure satisfies all of these from day one.

On the Netherlands specifically: we have supported a Dutch-licensed client through a DNB compliance review. The DNB's expectations are consistent with EBA guidelines: documentation, an accountability chain, EU data residency, and evidence of oversight. All of which we provide as standard. If you have a specific concern about your NCA's position, raise it in the scoping call and we will give you a direct answer.

How quickly can you mobilise a team?+
Small teams of 1 to 3 analysts can typically be mobilised within two weeks of engagement confirmation. This includes onboarding to your systems, review of your AML policies, and briefing on your customer typologies. Larger teams of 4 or more take 3 to 4 weeks. We have not missed a mobilisation deadline agreed at engagement start.
Where are your analysts based?+
All our analysts are EU-based, operating in CET/EET time zones. This matters for two reasons. Regulatory: EU data residency requirements are met by default. Operational: your team is reachable during your business hours without coordination overhead. We do not use offshore analysts.
Which EU jurisdictions and NCAs do you cover?+
We have operated across 10+ EU NCAs, including DNB (Netherlands), MFSA (Malta), Bank of Lithuania, CySEC (Cyprus), Central Bank of Ireland, Finantsinspektsioon (Estonia), KNF (Poland) and FCMC (Latvia). Our outsourcing structures are designed to satisfy EBA/GL/2021/05, which applies uniformly across all EU member states.
What does compliance officer support actually mean in practice?+
It depends on the engagement type. For licence-stage provision: a qualified, named compliance officer in post for the NCA pre-authorisation review, owning the AML programme from day one. For interim gap cover: continuity within two weeks of a departure, all statutory functions maintained. For fractional arrangements: a defined schedule of days per month, covering SAR review, board reporting, NCA correspondence and programme oversight. All engagements carry genuine statutory accountability, not a countersigning service from a distance.
How are team leads qualified?+
All engagement leads hold ACAMS certification (Certified Anti-Money Laundering Specialist) and bring a minimum of five years in hands-on regulated-sector compliance roles inside EMIs, payment institutions and licensed fintechs under active NCA supervision. The people managing your case have sat across the table from NCA examiners and written SAR reports that regulators reviewed.
How is data handled and where is it stored?+
All data remains within the EU throughout the engagement. Analysts access your systems on a least-privilege basis, using only what is necessary for their specific function. We sign a Data Processing Agreement before any access is granted, aligning to GDPR Article 28 requirements. All activity is logged with audit trails available to you at any time. No third-country transfers. No offshore processing.
What is your pricing model?+
KYC/ODD analyst teams are priced on a monthly fixed-rate basis per analyst, with no placement fees, no recruitment costs and no employer social costs on your side. The rate varies by seniority (analyst, senior analyst, QA lead). Compliance officer support is priced as a monthly retainer. Advisory and audit engagements are fixed-fee projects, scoped and agreed before work begins. We provide a written proposal with all costs before any engagement starts.
Do you work with companies that are not yet licensed?+
Yes. We frequently work with companies during the licensing process, building the AML infrastructure the NCA needs to see before granting a licence. This includes compliance officer appointment, AML programme documentation and KYC process design. We can also advise on jurisdiction selection for EMI or CASP licensing if that is still under consideration.
How are you different from a staffing agency?+
A staffing agency places a candidate and their involvement ends there. We provide a managed compliance function. Our team supervises the analysts, maintains quality standards, manages escalations, ensures regulatory currency and takes accountability for outcomes. If an analyst leaves, we replace them without disruption to your operation. The regulatory expertise sits with us, not just with the individual placed.
Get in Touch

Tell us your situation.
We'll tell you exactly
what you need.

Send us a brief message and a senior advisor will respond within one business day, with an honest assessment of which service fits your situation and what it will cost. No sales team. No obligation.

KYC/ODD teams operational from two weeks, no placement fees
Compliance officer support: interim, fractional, licence-stage
AML audit and programme design: fixed fee, written output
MiCA CASP AML: AML programme build and KYC teams for crypto CASPs
EU AI Act: written classification opinion, senior advisor assigned
All engagements: GDPR-compliant, EU data residency, no lock-in

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