Lesson 1Customer due diligence and onboarding controls: KYC, beneficial ownership, screening, EDD triggers for high-risk merchants like crypto and gamblingThis part tackles customer due diligence for merchants and partners, covering KYC, beneficial ownership, sanctions and PEP checks, EDD signals for high-risk areas, and continuous monitoring suited to payment processor operations.
Merchant KYC and verification controlsBeneficial ownership identificationSanctions and PEP screening at onboardingEDD for crypto, gambling, and high riskOngoing due diligence and refresh cyclesLesson 2Transaction monitoring and detection rules: typologies for payments and digital wallets, rule design, thresholds, and scenario developmentThis part centres on transaction monitoring for payment processors, including typologies for cards, alternative payments, and wallets, rule and scenario creation, thresholds, alert management, adjustment, and model oversight to spot laundering and fraud signs.
Payment and wallet AML typologiesDesigning rules and scenariosThreshold setting and calibrationAlert triage and investigation flowsModel validation and performance reviewsLesson 3Risk-based approach: risk appetite statements, risk tolerances, segmentation of customers and productsThis part explains how payment processors use a risk-based method, with risk appetite and tolerance declarations, customer and product grouping, scoring methods, and matching controls and monitoring strength to risk degrees.
Drafting AML risk appetite statementsDefining risk tolerances and limitsCustomer and merchant segmentationProduct and channel risk scoringLinking controls to residual riskLesson 4Reporting and escalation: internal suspicious activity reporting, senior management and board reporting, regulator communication protocolsThis part addresses reporting and escalation for AML and sanctions, covering internal suspicious reports, case escalation, information for leaders and board, and protocols for talking with regulators and bank partners.
Internal suspicious activity reportingEscalation criteria and timelinesManagement and board reporting packsRegulator communication protocolsReporting to sponsor banks and partnersLesson 5Sanctions compliance program elements: screening workflows, watchlist management, false positive tuning, blocking/filing proceduresThis part specifies sanctions compliance for payment processors, including screening setup, list handling, workflow arrangement, false positive cuts, and steps for blocking, rejecting, reporting, and recording sanctions choices.
Sanctions risk assessment for processorsName and payment screening designWatchlist sourcing and list governanceFalse positive reduction and tuningBlocking, rejecting, and reporting flowsLesson 6Policies and procedures: AML, sanctions screening, KYC, enhanced due diligence (EDD), transaction monitoring, data protection, recordkeepingThis part shows how to write and keep AML, sanctions, KYC, EDD, monitoring, data protection, and recordkeeping policies and procedures that are risk-focused, practical, version-managed, and matched to regulatory demands.
Policy hierarchy and ownership modelCore AML and KYC policy elementsSanctions and screening proceduresEDD and transaction monitoring SOPsVersion control and approval workflowLesson 7Training and competency management: role-based training curriculum, frequency, tracking and testing of effectivenessThis part covers role-specific AML and sanctions training for payment processors, including curriculum by role, frequency, methods, tracking, effectiveness tests, and fixes for poor results or control lapses.
Training needs analysis by role and riskDesigning AML and sanctions curriculaTraining frequency and refresher cyclesTesting knowledge and measuring impactTracking completion and remediation stepsLesson 8Governance and organizational structure: Board oversight, Compliance Officer responsibilities, escalation pathsThis part sets governance setups for AML and compliance in payment processors, defining board duties, Compliance Officer role, escalation routes, and committee frames for independent, supported control areas.
Board AML and compliance oversight dutiesCompliance Officer mandate and authorityThree lines of defense model in practiceEscalation paths and issue ownershipCompliance and risk committee structuresLesson 9Recordkeeping and auditability: retention requirements, audit trails, change control for rules and modelsThis part explains recordkeeping and audit needs for AML programs, covering retention plans, safe storage, trails for decisions, and change oversight for rules, models, and data to aid regulator and internal audits.
Regulatory record retention requirementsDesigning searchable audit trailsEvidence of investigations and decisionsChange control for rules and modelsData lineage and system-of-record controls
