LTB

Legal

Reviewers keep flagging our AML and KYC documentation.

Licensing assessors and bank onboarding teams read the same three documents: the AML and CTF policy, the customer due diligence procedure, and the risk assessment behind them. A downloaded template fails on contact with either, because both reviewers test whether the document describes the business in front of them: its payment methods, its player or customer geographies, its transaction sizes, its actual escalation path.

The recurring deficiencies are specific. No documented risk-based tiering, so every customer receives identical checks. No named MLRO with evidenced authority and reporting line. No enhanced due diligence trigger set for politically exposed persons or high-value deposits. No record of ongoing monitoring or periodic refresh. No transaction-monitoring thresholds that anyone can point to in a system.

Because banking and licensing draw on the same file, one weak framework produces two separate refusals, often months apart, and each refusal makes the next reviewer more cautious.

How LTB Resolves It

LTB conducts a documentary review against the standards the reviewer will apply (the relevant regulator's guidance and the onboarding criteria of the institutions likely to receive the file) and produces a written gap list with each gap tied to its source requirement.

The practice then rewrites the framework as an operational one: a business-specific risk assessment, tiered customer due diligence with defined enhanced triggers, a documented MLRO function, monitoring thresholds, record-retention rules, and a training and testing schedule. Where an independent audit, an MLRO appointment, or a monitoring system is required, the work is placed with the compliance professional or provider in LTB's network qualified to carry it out, coordinated throughout by LTB.

Questions

Frequently Asked

It removes the most commonly cited ground. Whether the application is reopened also depends on the institution, the structure, and whether a prior listing or closure sits on the record, which is assessed at the same time.

No. LTB structures the framework and documents the function. Where an appointed officer or an independent audit is required, that role is filled by a qualified professional in the practice's network.

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