Lesson 1Customer due diligence and onboarding controls: KYC, beneficial ownership, screening, EDD triggers for high-risk merchants like crypto and gamblingThis part deals with checking customers like merchants and partners, including know your customer, beneficial owners, sanctions and PEP checks, extra due diligence for high-risk areas, and ongoing monitoring fit for payment processor ways.
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 looks at transaction monitoring for payment processors, covering patterns for cards, alternative payments, and wallets, designing rules and scenarios, setting limits, handling alerts, adjusting, and managing models to spot money laundering and fraud.
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 describes how payment processors use a risk-based way, including statements on risk appetite and tolerance, grouping customers and products, scoring methods, and matching controls and monitoring strength to risk levels.
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 covers reporting and raising issues for anti-money laundering and sanctions, including internal suspicious reports, case raising, info for leaders and board, and ways to talk 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 details sanctions compliance for payment processors, including screening setup, list handling, workflow setup, reducing false alerts, and steps for blocking, rejecting, reporting, and recording sanctions decisions.
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 explains how to write and keep anti-money laundering, sanctions, know your customer, extra due diligence, monitoring, data protection, and record policies and steps that are risk-based, practical, version-controlled, and match regulator needs.
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-based anti-money laundering and sanctions training for payment processors, including curriculum by job, how often, delivery ways, tracking completion, testing results, and fixing low scores or control issues.
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 defines management structures for anti-money laundering and compliance in payment processors, making clear board duties, Compliance Officer role, raising channels, and committee setups that ensure independent, well-supported control functions.
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 checkability needs for anti-money laundering programmes, including keeping schedules, safe storage, trails for key decisions, and change control for rules, models, and data to help regulator and internal checks.
Regulatory record retention requirementsDesigning searchable audit trailsEvidence of investigations and decisionsChange control for rules and modelsData lineage and system-of-record controls
