We provide outsourced KYC and ODD analyst teams to EMIs, payment institutions and fintechs across the EU. Fully remote, aligned to your AML policies, ready in two weeks. Fixed monthly rate per analyst, no placement fees, 30-day scale-down clause.
Outsourcing is not always the right solution. When it is, the decision is usually clear. These are the profiles where we add the most value, fastest.
Customer acquisition is outpacing your KYC capacity. You need more analysts now, not in three to six months after a recruitment cycle. We are live in two weeks and scale with your volumes.
Driver: Volume growthTimeline: ImmediateAn upcoming audit or examination. A backlog of periodic ODD reviews, case documentation gaps or a TM alert queue that needs clearing before examiners arrive. We have done this under Bank of Lithuania, MFSA and Finantsinspektsioon examinations.
Driver: Regulatory pressureTimeline: UrgentThe NCA wants to see a functioning KYC operation before granting a licence. We build and staff that operation in time to meet your application timeline, without you committing to permanent headcount before you have revenue to support it.
Driver: Licence applicationTimeline: 2–4 weeksA backlog of outstanding CDD, EDD or periodic ODD reviews has accumulated. The internal team cannot clear it without compromising ongoing onboarding. We deploy a dedicated clearance team for a defined project period and scale back on completion.
Driver: Operational backlogTimeline: 2 weeksCrypto customer onboarding has requirements that generic KYC analysts are not calibrated for: unhosted wallet attribution, Travel Rule counterparty identification, blockchain analytics integration and DeFi customer profiling. Our crypto-specialised team covers all of these.
Driver: MiCA / CASP registrationTimeline: 2–4 weeksHigh false-positive rates, declining EDD case quality, SARs being missed or documentation that would not survive an NCA review. We supplement or replace the function and provide the QA infrastructure to maintain standards going forward.
Driver: Quality failureTimeline: ImmediateMost clients call us when a specific pressure point makes the internal hiring path impractical: a timeline that recruitment cannot meet, a regulatory deadline, or a cost structure that a permanent hire does not fit.
In-house hiring is the right answer when your KYC volumes are stable and predictable, you have 3 to 6 months to recruit and onboard, and you have the HR and management capacity to run a compliance team as a permanent internal function. Most growth-stage regulated firms do not meet all three conditions simultaneously.
Outsourcing is right when you need to be operational in weeks, not months; when volumes are variable and you need scale-up and scale-down flexibility; or when you want to avoid permanent headcount until your revenue justifies it. For most EU-regulated fintechs at growth stage, this is the more rational first move.
The decision is not always binary. Many clients start with an outsourced team, run it for 12 to 18 months, and bring functions in-house selectively once volumes and team requirements are stable. We support that transition when it comes.
Discuss your situationAn audit or examination date has been set and your KYC function is not examination-ready. Backlog, documentation gaps or quality issues that will surface in examination. We have mobilised teams in 10 days in this situation.
The NCA needs to see a functioning KYC team before granting a licence. Your application timeline is fixed. Recruitment will not get you there. We can staff the function for the application period and continue post-licence.
Your customer acquisition is outpacing your existing KYC capacity. The backlog is growing. Your current analysts are working through a queue that is getting longer, not shorter. A team of 2 to 3 analysts clears that backlog in weeks.
High false-positive rates, declining case quality, or a key analyst has left. You need continuity. We step in, maintain the function without interruption, and bring QA infrastructure that the team may not have had before.
An NCA examination has produced findings requiring specific remediation: periodic ODD backlog, enhanced screening coverage, or TM alert disposition quality. We target these gaps specifically with the right analyst profile.
Compliance headcount is expensive to justify before a firm hits a certain scale. An outsourced team at a fixed monthly rate is far easier to defend in a board discussion than 3 to 5 full-time permanent hires with employer costs.
Your MiCA registration requires demonstrable KYC substance. Crypto customer onboarding, wallet attribution, Travel Rule, on-chain monitoring, requires analysts with specific experience that generalist KYC hires rarely have.
Book a free 30-minute scoping call. We assess your current KYC capacity, regulatory obligations and volume trajectory and tell you honestly whether outsourcing fits, including what team size, seniority and configuration makes sense. No obligation to proceed.
We were facing a Bank of Lithuania examination with a backlog of 400+ periodic ODD reviews and eight weeks to clear it. They deployed four analysts within ten days, cleared the backlog two weeks before the examination date, and the NCA found no material issues with our KYC function.
A recruiter places a candidate. Their involvement ends at placement. You then own the HR management, training, quality oversight and retention. If the analyst leaves, you start again. We provide a managed function: we supervise the team, maintain quality standards, manage escalations and replace departing analysts without disruption. The regulatory expertise stays with us, not with the individual placed.
Our analysts work inside your systems, under your AML policies, and report to your MLRO. They are not external advisors sending recommendations. They do the work.
Full CDD for individual and legal entity customers. Identity verification, beneficial ownership analysis, source of funds assessment, and risk classification against your risk appetite framework.
EDD for customers flagged as high-risk: PEPs, high-risk jurisdictions, complex ownership structures and unusual transaction patterns. Structured case files with documented reasoning.
Screening against OFAC, EU, UN and national sanctions lists, PEP databases and adverse media sources at onboarding and on a triggered basis throughout the customer lifecycle.
Scheduled and risk-triggered reviews of existing customer files. Risk reclassification where circumstances have changed. Updated documentation to reflect current customer profile and activity.
First-line review and triage of transaction monitoring alerts. Disposition of low and medium-risk alerts with documented reasoning. Escalation of complex or high-risk cases to your MLRO.
Structured case management with full audit trail. Preparation of SAR support files for MLRO review and submission. Escalation protocols calibrated to your internal procedures.
Application of your risk appetite framework to new and existing customers. Documented risk ratings, rationale and escalation thresholds. Consistent application across the team via QA review.
A named ACAMS-certified team lead reviews output daily, runs weekly QA sampling and provides a written performance report each month. You see the quality metrics, not just the throughput numbers.
Rapid deployment for KYC backlogs ahead of NCA examinations, licence renewals or period-end reviews. Teams can be mobilised specifically for a defined clearance project and scaled back on conclusion.
Three structures, one question: how predictable are your KYC volumes? Your answer determines which model is right. All three include the same QA framework, ACAMS-certified team lead and NCA-accepted outsourcing documentation.
Full-time EU-based analysts embedded in your compliance function under agreed SLAs, reporting cadence and throughput targets. The default model for firms with ongoing onboarding volumes or a continuous ODD review cycle.
A pre-committed block of analyst capacity for a defined period: NCA examination preparation, licence application, backlog clearance or a specific ODD review cycle. We manage rota and coverage within the block. Fixed scope, fixed fee.
Pay per completed case or alert disposition, with agreed quality controls and turnaround targets. Transparent unit economics and volumes that scale with your actual workload rather than a fixed headcount. Suited to event-driven or seasonal KYC patterns.
Whichever model you choose, the operational structure is the same: your systems, your policies, ACAMS-certified supervision, documented QA and a clear escalation path to your MLRO.
Analysts access only your case management and KYC systems, with least-privilege credentials scoped to their function. No customer data is stored in our infrastructure. All processing stays within the EU. GDPR Art. 28 DPA signed before any access.
Every engagement has a named ACAMS-certified team lead who reviews output daily, conducts weekly QA sampling against your standards, and provides a written monthly performance report. You receive metrics, not just throughput numbers.
When onboarding volumes increase, we add analysts with a 1 to 2-week briefing period per additional team member. No recruitment process on your side. No induction overhead. For larger increases, 3 to 4 weeks depending on team size.
Scale back with 30 days notice from any point. No termination fee, no redundancy exposure, no HR process. The analyst is redeployed internally. No disruption to the function during the transition period.
EBA/GL/2021/05 and AMLD6 explicitly permit outsourcing of KYC and CDD functions. NCAs including the DNB, Bank of Lithuania and FCA have accepted such structures in practice. What they require is documented governance, not in-jurisdiction analysts.
The legal basis: Article 25 of AMLD6 and EBA/GL/2021/05 explicitly permit regulated entities to outsource AML/KYC functions to third parties, provided the arrangement is documented, supervised, auditable, and ultimate accountability is retained by the regulated entity. This applies uniformly across all EU member states. No NCA can prohibit it; they can only require it to be structured correctly.
A documented contract specifying obligations, service levels and audit rights. Our team provides a GDPR Art. 28-compliant DPA and outsourcing agreement before any work begins.
The outsourcing does not transfer your regulatory licence obligations. Your MLRO retains accountability. Our team executes under your policies and your oversight structure.
Weekly QA reports and monthly performance reviews provide regulators with evidence of active supervision. Our engagement structure explicitly provides for NCA examination of the outsourced function.
We scope before we propose. Every engagement starts with understanding your regulatory framework, current infrastructure and gap, so the team we provide is configured to your actual situation.
We review your AML framework, regulatory obligations and current KYC capacity. You receive a written proposal with team configuration, timelines and fixed monthly rate within two business days.
We review your AML policies, access your systems with least-privilege credentials and brief the team on your risk appetite and customer typologies. NDA and GDPR DPA signed before any access is granted.
Your team begins working your case queue: CDD, EDD, PEP and sanctions screening, ongoing monitoring. The team lead runs daily QA. Escalations handled same-day. Weekly reporting to your MLRO.
Monthly performance review against your AML KPIs. Team scales up or down with appropriate notice. Regulatory changes flagged and your programme updated as needed.
Timeline note: Teams of 1 to 3 analysts are typically live within two weeks of engagement confirmation. Larger teams of 4 to 10 typically take 3 to 4 weeks due to the additional briefing and QA calibration required. We have not missed a mobilisation deadline agreed at engagement start.
For most EU-regulated firms at growth stage, outsourcing is the faster, cheaper and lower-risk path to a functioning KYC operation. The in-house model makes sense when you have predictable, stable throughput and the management bandwidth to run a compliance function as an internal team.
An upcoming audit or inspection. We assess the gap and, where needed, embed analysts to clear the backlog before examiners arrive. We have done this for clients across Malta, Lithuania and Estonia.
The NCA wants to see a functioning KYC team before granting or renewing a licence. We can provide that team fast enough to meet the application timeline, without you committing to permanent headcount.
Onboarding volumes outpacing your KYC capacity. We scale the team in two to four weeks. No recruitment cycle, no quality dip during the transition.
High false-positive rates, case backlogs or SAR quality issues. We supplement or replace the function and provide the QA infrastructure to prevent recurrence.
Most compliance leaders have reasonable concerns about outsourcing KYC. Almost all of them are based on assumptions that do not survive contact with how a well-structured engagement actually runs. These are the objections we address in every scoping call.
A generic analyst pool applying a one-size-fits-all approach to CDD and EDD, producing output that does not reflect your risk appetite or customer typologies.
The first week of every engagement is a structured onboarding: your AML policies reviewed, your systems accessed with least-privilege credentials, your customer segments and risk factors briefed. The team lead runs a calibration session before case work starts. Output is benchmarked against your standards, not ours.
Onboarding week included in every engagementOutsourcing KYC is a regulatory grey area and our NCA, especially DNB or the Central Bank of Ireland, will take issue with the arrangement.
No NCA can prohibit it. What they require is governance: a written outsourcing agreement, a GDPR-compliant DPA, EU data residency, quality oversight documentation, and a clear escalation path to your MLRO. Our engagement structure provides all of these as standard. We have supported clients through NCA examinations at DNB, MFSA, Bank of Lithuania and Finantsinspektsioon, the outsourcing arrangement was not raised as a concern.
EBA/GL/2021/05 · AMLD6 Article 25Once analysts are outside our direct line management, output quality becomes opaque. We lose visibility into case quality and cannot demonstrate oversight to our MLRO or NCA.
Every engagement includes: daily QA review by the ACAMS-certified team lead, a weekly QA sampling report with case-level metrics, a monthly performance review against agreed KPIs, and full case documentation maintained in your systems. Most internal KYC teams do not produce written QA metrics at this frequency. The NCA sees the documentation, not just throughput numbers.
Weekly QA report · Monthly performance review · Full audit trailCustomer data accessed by a third-party team creates GDPR exposure and data security risks that our DPO will not accept.
All analysts access customer data through your systems only, with credentials scoped to their specific function. No customer data is copied, stored or processed in our infrastructure. We sign a GDPR Article 28-compliant Data Processing Agreement before any access is granted. All analysts are EU-based. Activity is logged with full audit trail available to you and your DPO at any time.
GDPR Art. 28 DPA · Least-privilege access · EU data residencySetting up a third-party team with system access, policy briefings and quality calibration takes as long as a recruitment process.
The two-week timeline is not theoretical. It includes: NDA and DPA signed, system access provisioned, AML policies reviewed, customer typology briefing completed, and first case output produced. Larger teams of 4 to 10 take 3 to 4 weeks. A recruitment process for a single qualified KYC analyst in most EU markets takes 8 to 16 weeks from posting to start date.
2 weeks (1–3 analysts) · 3–4 weeks (4–10 analysts)Once we've committed to an outsourced team, scaling back will be contractually difficult or costly.
There is no minimum ongoing contract beyond the initial scope period agreed at proposal stage. Scale-down of individual analysts requires 30 days notice. The departing analyst is redeployed internally, no redundancy on your side, no awkward exit process. Compare this to a permanent hire: typically 3 to 6 months notice, potential redundancy liability, and an internal HR process. Outsourcing gives you flexibility that headcount does not.
30-day scale-down · No penalties · No redundancy exposureRecognise any of these concerns? They come up in almost every initial scoping call. We address each one directly, before any engagement begins. The free call costs nothing and takes 30 minutes. Understanding whether outsourcing actually fits your situation is the only useful starting point.
Book the Free CallThree client engagements, different situations, same result: faster compliance, lower cost and regulatory pressure resolved.
A top-5 Lithuanian-licensed EMI had accumulated a critical transaction monitoring backlog with an NCA audit imminent. Previous fines had reached €500,000 to €600,000. Our team deployed a dedicated ACAMS-supervised AML team within two weeks. KPI targets were exceeded by 30% weekly. Operational control was restored ahead of the audit date.
A high-growth EU payment institution had accumulated an extensive ODD and EDD backlog across a high-risk customer base. Our team scaled from an initial 2-analyst deployment to 12 within 30 days, building custom SOPs and a training methodology for long-term quality. All targets were met one week ahead of the agreed deadline.
A licensed EU EMI outsourced its entire first-line KYC and ODD function: onboarding, ongoing due diligence, transaction monitoring, QA and internal audit to our team as a long-term managed service. The engagement replaced an equivalent in-house team at 40 to 50% lower total cost, with no recruitment overhead.
References available on request for qualified prospects. All case data verified by engagement records.
Discuss Your SituationWe 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.
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.
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.
As a Cyprus-licensed PI we needed a KYC/ODD team that understood CySEC expectations and AMLD6 requirements simultaneously. Both were met. Ongoing EDD reviews and high-risk customer monitoring are handled consistently. The cost compared to expanding our internal team is significantly lower, and the regulatory quality is higher than what we had before.
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Yes, and this is the question we hear most often. Outsourcing KYC and CDD functions is explicitly permitted under AMLD6 and EBA/GL/2021/05, uniformly across all EU member states.
What regulators require is not where your analysts sit, but how the arrangement is governed: a written outsourcing agreement, a GDPR-compliant DPA, documented quality oversight, a clear escalation path back to your MLRO, and the ability for the NCA to examine the outsourced function as part of your broader AML inspection. Our engagement structure is built to satisfy all of these from day one.
On the Netherlands specifically: we have supported a Dutch-licensed client through a DNB compliance review. DNB's expectations are consistent with EBA guidelines: documentation, accountability chain, EU data residency and evidence of oversight. All provided as standard. If you have a concern about your NCA's position, raise it in the scoping call and we will give you a direct answer.
A senior advisor will assess your situation and come back with an honest view: which team configuration fits, what it will cost, and how quickly we can mobilise. No sales team. No obligation.
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