01
Prepaid, reload and redemption
Identify structuring, fast cycles, third-party use and exits without clear economic purpose.
AML/CFT for EMIs
E-money changes the shape of risk.
Not the effectiveness standard.
A risk assessment designed for EMIs: prepaid value, reloads, redemption, cards, digital onboarding, vIBANs and cross-border movement.
Scoping callAML/CFT for EMIs
Priority EMI scenarios
02
Remote onboarding and KYC
Test data reliability, documentary consistency, rejections and escalation of higher-risk cases.
03
Cards and payment instruments
Connect limits, countries of use, cash-like use, frequency anomalies and blocking decisions.
04
vIBANs and payment accounts
Control allocation, third-party use, inbound/outbound flows and pass-through accounts.
05
Distribution programme
Assess partners, execution of delegated controls and actual alert escalation.
06
Customer profile and review
Evidence that risk rating, EDD thresholds and periodic reviews follow behavioural change.
From risk to evidence
Every scenario is linked to the expected control, an operating-effectiveness test and the evidence that demonstrates execution.
01
Risk
Scenario, driver and inherent exposure.
02
Control
Preventive or detective measure, owner and frequency.
03
Test
Population, method, acceptance threshold and finding.
04
Evidence
Dated, traceable material reusable during scrutiny.
What you receive
A working framework for annual classification, control planning and remediation.
Sector risk assessment and residual score
L1 / L2 control plan, key controls and owners
L3 test programme, populations and sampling
Evidence, findings, actions and retest register
Framework informed by FATF recommendations, applicable EU rules and relevant French expectations; it is tailored to your risk profile and obligations.
Scoping call
Turn risk into controlled evidence.
Share your perimeter, timing and priority risk areas. No customer data is needed for the first conversation.
Framework informed by FATF recommendations, applicable EU rules and relevant French expectations; it is tailored to your risk profile and obligations.