Replaces the £40,000–£100,000/year outsourced MLRO retainer.
Ten tabs covering AML, CDD/EDD, Transaction Monitoring, Sanctions, SAR/STOR, ABC, Fraud, Market Abuse and Tax Evasion. 30 FCA-minimum controls, 132-question Gap Analysis, 27 pre-seeded high-risk jurisdictions — and five Anna-generated regulator-grade reports (MLRO Annual, REP-CRIM, Board Quarterly, Executive Summary, Comprehensive) drafted from your live registers, not templated placeholders.
£500/month · Add to any RegTechPRO subscription · Cancel any time
If your MLRO workflow lives in spreadsheets, Outlook folders, and a £60k-a-year outsourced consultant — you're one FCA supervisory letter away from a very bad month. This is where most small FCA-regulated firms are stuck.
Customer risk, PEP register, UBO list, sanctions hits, SAR log, G&H, third-party DD — every MLR 2017 obligation scattered across workbooks nobody version-controls. When the FCA asks for your 5-year evidence trail, you're flicking between FINAL_v7 and an email thread.
Outsourced MLRO functions bill £40k–£100k a year. A one-off AML gap analysis is another £15k–£25k. You still carry the SMF17 risk, you still sign the MLRO Annual, and the consultant still hands you back a Word doc every December.
SAMLA 2018 is strict liability. A confirmed sanctions match means OFSI within 24 hours, a detailed report in 21 days, and frozen-funds report inside a month. If you're still emailing the sanctions screener asking “is this a true hit?” — you're already late.
The 14-section MLRO Annual Report under JMLSG takes an experienced MLRO 3–5 days to write from scratch each year. REP-CRIM. Board quarterly. Audit findings. Training matrices. The regulatory reports never stop arriving — and they're all due at once.
If your MLRO workflow currently lives in spreadsheets, a consultant's inbox, and the fortnight before the FCA supervisory visit — the Financial Crime Suite is for you.
Most financial-crime tools ship templates and generic AI. Financial Crime Suite is built on three principles that let Anna draft regulator-grade reports — live-data grounding, a structured gap instrument, and coverage across every UK financial-crime regime.
Every MLRO report is drafted from the firm's own live state — 25 structured data arrays serialised and sent to Anna with the instruction: *"Use ONLY the data provided — do not invent examples."* PEPs appear by name, registers render as tables, and output is a 14-section Annual MLRO Report (JMLSG), REP-CRIM, Board Quarterly, Executive Summary or Comprehensive Hybrid. ChatGPT cannot do this.
JMLSG-aligned · 5 report formats · Live-grounded132 structured questions across 14 chapters, each Anna-remediable with a prioritised Critical/High/Medium/Low action plan that cites MLR 2017, POCA, SAMLA, Bribery Act, CFA 2017, UK MAR, FCG or JMLSG by regulation. Firms that pay £15k–£25k for a one-off AML gap consultancy get the same instrument here, always on, tracked, with evidence notes attached per answer.
MLR 2017 · 132 questions · 14 chaptersAML, CDD/EDD, Transaction Monitoring, Sanctions, ABC, SAR/STOR, Market Abuse, Tax Evasion and Anti-Fraud — every UK financial-crime obligation in one module, with a pillar-weighted Health score (customisable weights, RAG thresholds fixed at 80/50, deterministic maths) so the Board sees real strength and weakness, not an AI-judged number.
SYSC 6.3 · SAMLA 2018 · POCA ss 330–336One living record across 10 tabs and 36 accordion sections. 30 FCA-minimum controls, 132-question Gap Analysis, 27 pre-seeded high-risk jurisdictions, 10-policy governance library — every register, every obligation, every piece of evidence feeding Anna's five regulator-grade report formats.
A 30-second MLRO view of the firm: Financial Crime Health score (60% pillar composite + 40% FCA-minimum checklist), all 10 weighted pillars with RAG bars, the 30-control compliance checklist, and the six Key Review Dates — REP-CRIM +60 days post-YE, sanctions 31 Mar, MLRO annual — all on one screen.
The 14-section MLRO Annual Report under JMLSG — Anna drafts every section from your live registers. PEPs named from your PEP register, sanctions hits from your screening log, SARs from your NCA submissions, training from your matrix. Export to PDF, sign, file. Plus four more formats: REP-CRIM, Board Quarterly, Executive Summary, Comprehensive.
The built-in Financial Crime horizon feed: FCA, OFSI, HMT, FATF, NCA and JMLSG publications aggregated in one place. OFSI list updates, enforcement notices, Dear MLRO letters — with a direct route from headline to Horizon & Whistleblowing register entry, with impact, owner and target date.
The JMLSG-aligned annual report the FCA will ask for under SYSC 6.3 — drawn from your live BWRA, CDD registers, TM alerts, sanctions hits and SAR log, with every claim mapped to MLR 2017, POCA, SAMLA and the Bribery Act. Three days of MLRO drafting compressed into one SMF17 review cycle.
Anna drafts all 14 sections of the JMLSG-aligned MLRO Annual Report from your own 27 register arrays — BWRA ratings, customer risk segments, PEP population, TM alerts, sanctions hits, SARs raised and DAML outcomes. Each section cites MLR 2017, POCA, SAMLA, Bribery Act, CFA 2017, UK MAR, JMLSG or the FCG so the supervisor can trace every claim to its statutory source.
The NCA and the FCA both ask the same question on every supervisory visit: show us your disclosures log. Here it is — MLRO-decisioned within 72 hours, cross-referenced to the customer file, and preserved beyond the five-year MLR retention floor.
| Raised by | Disclosure / alert | Date raised | Status |
|---|---|---|---|
|
Amina Okonkwo
Onboarding Analyst · 1LoD
|
Internal SAR: UBO on corporate onboarding declined source-of-wealth question twice; PEP proximity flagged on OFSI rescreen. | Mar 24, 2026 | DAML filed |
|
Rajesh Iyer
TM Analyst · 2LoD
|
Structuring pattern on MID-risk SME — 14 sub-£10k inbound faster payments in 7 days against a £38k historic monthly average. | Mar 12, 2026 | MLRO review |
|
Helena Brandt
Sanctions Officer · 2LoD
|
OFSI 94% fuzzy match on beneficiary account — name variant on Russia SSI list. Payment quarantined; OFSI notified within 24 hrs. | Feb 27, 2026 | Cleared |
|
Daniel Acheampong
Deputy MLRO · SMF17 cover
|
Tipping-off risk escalation: relationship manager asked about account freeze reason; POCA s333A briefing re-delivered firm-wide. | Feb 14, 2026 | Resolved |
|
Priya Narayanan
Head of Compliance · 2LoD
|
External SAR to NCA: politically exposed client instructed third-country transfer inconsistent with stated wealth source. | Jan 30, 2026 | NCA acknowledged |
MLR 2017 reg 21 and SYSC 6.3 demand personal accountability — not a committee. The MLRO (SMF17) confirms adequacy, the senior manager responsible for financial crime (SMF2) counter-signs, and the CEO (SMF1) attests. Once locked, the report is immutable and reproducible across the NCA’s five-year MLR retention window.
AML, CDD/EDD, Transaction Monitoring, Sanctions, SAR/STOR, ABC, Fraud, Market Abuse, Tax Evasion — the BWRA, the 25 live registers, the 30-control FCA-minimum checklist, the 132-question Gap Analysis, the 10-policy governance library, and Anna's five regulator-grade report formats.
A senior MLRO would spend 3–5 days writing this from scratch. Anna drafts every section from your registers — PEPs named from your PEP register, sanctions hits from your screening log, SARs from your NCA submissions — per-section regenerate, export to PDF.
60% pillar composite plus 40% FCA-minimum checklist — RAG-banded at Green ≥80, Amber 50–79, Red <50. Customise the pillar weights to your own risk profile; the score recomputes live.
A PI/EMI can weight Sanctions to 30; a wealth manager can push CDD to 22; an IFA can drop TM to 8. The defaults reflect FCA enforcement priorities — but the sliders are yours. Every weight change recomputes the Health score live.
The 30-row FCA-minimum grid: MLRO at management level, UBO at 25%, EDD for PEPs, OFSI within 24 hours, SAR process, ABC six MoJ principles, CFA 2017 reasonable prevention. Every row cites the exact UK source — MLR 2017, POCA, SAMLA, Bribery Act, CFA 2017, UK MAR, JMLSG, FCG.
| Control | Regulatory source | Status |
|---|---|---|
| MLRO appointed (SMF17) | MLR 2017 reg 21(3) | Met |
| UBO > 25% verification | MLR 2017 reg 28 | Met |
| EDD for PEPs + SoW | MLR 2017 reg 33/35 | Met |
| OFSI 24-hr notification | SAMLA 2018 s 21C | Met |
| DAML procedure | POCA 2002 ss 335–336 | Met |
| ABC six MoJ principles | Bribery Act 2010 s 7 | Partial |
| CFA 2017 prevention | CFA 2017 s 45/46 | Met |
Strict liability under SAMLA 2018. Fuzzy match, onboarding + transaction + rescreen, full hit-log with match score, investigator, approver, disposition.
Internal SAR within 24 hrs, MLRO decision within 72 hrs, NCA without delay, DAML 7-day + 31-day moratorium, STOR to FCA within 1 working day. POCA ss 330–336 · UK MAR Art 16 · Terrorism Act 2000 s 21A.
% transactions and % customers monitored, tuning cadence, typologies watchlist, alert investigation SLAs (high 24h / medium 72h / low 5 bd). JMLSG Pt I 5.7 · MLR 2017 reg 28(11).
MLR 2017 reg 18 BWRA across customer, product, geographic and delivery-channel risk — with 27 high-risk jurisdictions pre-loaded: FATF Call-for-Action (3), Comprehensive UK sanctions (2), FATF Grey List (22). Data firms normally buy from vendors — shipped.
132 structured questions across 14 chapters — Governance, MLRO, Training, CDD/EDD, BWRA, TM, Sanctions, SAR/STOR, ABC, Fraud, MAR, Tax, Record Keeping, Third Parties. Met / Partial / Not Met / N/A with evidence notes, plus “+ Generate remediation plan (Anna AI)”.
Customer Risk, PEP, UBO >25%, and EDD Case File — dual SMF17 + SMF1 PEP approval matrix, SoF/SoW verification, ongoing-monitoring cadence.
AML · CDD · Sanctions · ABC · G&H · Anti-Fraud · Market Abuse · Tax Evasion · STOR Manual · AML Gap Analysis Manual — each with its statutory anchor and Board-approved date.
Bribery Act 2010 s 7 “adequate procedures” — Line Manager / Senior Manager + EDD / Compliance + risk + sanctions / SMF holder + Board + legal review. Associated persons, third-party DD, conflicts register under SYSC 10.
Fraud Act 2006 internal & external typologies, UK MAR surveillance with 11 scenarios and 15% random comms sampling (7-year retention per MiFID II), Insider List, PA Dealing with 30-day holding, Chinese Walls, and CFA 2017 reasonable prevention procedures for UK and foreign tax evasion.
MLR 2017 reg 24 — financial crime training for all staff within 30 days of joining, annual refresher, records retained 5 years. Staff-by-staff completion, score and next-due, auto-flagged in the MLRO Annual Report.
Policy annual review · BWRA next review · Sanctions review (31 Mar YYYY+1) · REP-CRIM (+60 days post year-end, SUP 16.23) · MLRO annual report · Independent audit — computed from your data and pinned to the dashboard strip.
Every generation uses your firm’s actual registers — BWRA ratings, PEP populations, TM alerts, sanctions hits, SARs filed — not templated placeholders. Per-section regenerate means refining just the Sanctions section if OFSI adds a designation; the rest of the report stays intact.
Every Anna generation serialises your full module state — all 25 registers, 36 section statuses, 10 pillar weights, 132 gap-analysis answers — and grounds the output in it. System prompt: “Use ONLY the data provided — do not invent examples.” Tables are built from your registers. When your data changes, the next generated section changes with it. Generic AI tools can’t do this without the structured-data pipeline this module already is. That’s the moat.
£500/month · Add to any RegTechPRO subscription · Cancel any time
Anna is trained on MLR 2017, POCA 2002, SAMLA 2018, Bribery Act 2010, CFA 2017, UK MAR, JMLSG and FCG. She answers AML, sanctions, PEP, UBO and SAR questions in seconds — cited to statute — and writes every section of your MLRO Annual Report (plus REP-CRIM, Board Quarterly, Executive Summary and Comprehensive) from your own live registers.
Anna does two things for Financial Crime. First, she’s on call to answer any AML, CDD/EDD, PEP, sanctions, SAR or market-abuse question your team throws at her — cited to MLR 2017, POCA, SAMLA, Bribery Act, CFA 2017, UK MAR, JMLSG or FCG. Second, she drafts the 14-section MLRO Annual Report (plus four more regulator-grade formats) from your firm’s own live registers — naming your actual PEPs, your actual sanctions hits, your actual SARs.
“When does EDD trigger under MLR 2017 reg 33?” “Do we need to file a DAML before releasing this payment?” “Is this OFSI hit a true match — what do we do in 24 hours?” Anna answers from MLR 2017, POCA, SAMLA, the Bribery Act, JMLSG and your live Financial Crime data — in seconds, with citations.
She writes the 14-section MLRO Annual from your live registers, produces REP-CRIM and the Board Quarterly on demand, and answers any AML, sanctions or SAR question your team asks — cited to statute. See her draft your MLRO Annual in a live demo.
From MLROs to Heads of Financial Crime — how firms are replacing outsourced AML consultants and spreadsheet BWRAs with a single live MLRO operating system.
I used to spend the first week of every year writing the MLRO Annual from scratch — flicking between the PEP workbook, the sanctions log, the SAR folder and half a dozen emails. Now Anna drafts all 14 sections from our live registers and I sign it. The BWRA, the 30-control checklist and the Gap Analysis sit in one place, and I can answer an FCA supervisor's question in 30 seconds instead of 30 minutes.
We were paying £78k a year for an outsourced MLRO function that produced a Word doc every December. I trialled the Financial Crime Suite against our existing data, did the 132-question Gap Analysis in an afternoon, and Anna drafted a better MLRO Annual than the consultant had ever delivered. £500 a month instead of £6,500. The sanctions and SAR registers alone are worth the subscription.
Everything you need to know about the MLRO workflow, Anna’s 14-section report, the Gap Analysis, and how the module sits inside MLR 2017, POCA and SAMLA.