AML and Compliance Programmes for Licensed Firms: Legal Advisory

A GFSO licence is granted and kept on the strength of the compliance framework behind it, so the AML manual, the monitoring plan and the MLRO appointment are not paperwork but the thing the regulator actually inspects. Basnet Law designs and documents the anti-money laundering and compliance framework a Licensed Firm must have under the Financial Services Act 2025, the General Rulebook and the AML and Sanctions Rulebook.

Draft the AML manual describing internal controls against money laundering, terrorist financing, proliferation financing, financing of unlawful organisations and sanctions non-compliance, as GFSO's published guidance expects.

Design customer due diligence, risk rating, monitoring and record-keeping procedures that meet the AML obligations in the Financial Services Act 2025.

Document the compliance function, its resources and reporting lines under the GEN Rulebook, with a monitoring programme.

Write the whistleblowing policy the GEN Rulebook requires, with the six-year record retention.

Define the Money Laundering Reporting Officer role under the GEN Rulebook and advise on the Approved Person requirements.

Build the beneficial ownership process, using the "registrable controller" framework as the reference model, and train staff so the SEO, Compliance Officer and MLRO can demonstrate AML knowledge.

Applicants at the IPA stage that must evidence systems and controls before the Financial Services Licence issues. Virtual asset firms, custodians and exchanges facing enhanced scrutiny on source of funds and sanctions. Fund managers, advisers and arrangers building a proportionate programme for a small team. Existing Licensed Firms remediating findings or preparing for a GFSO review. DNFBPs (law, accounting, real estate, high-value dealers, CSPs, NPOs) that must register with GFSO and build a proportionate programme.