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 associates, covering KYC, beneficial ownership checks, sanctions and PEP screening, EDD prompts 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 concentrates on transaction monitoring for payment processors, addressing typologies for cards, alternative payment methods, and wallets, rule and scenario creation, thresholds, alert management, tuning, and model oversight to spot money laundering and fraud indicators.
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 implement a risk-based method, incorporating risk appetite and tolerance declarations, customer and product grouping, scoring approaches, and matching controls and monitoring vigour 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, including internal suspicious activity reports, case advancement, information for executives and the board, and protocols for engaging regulators and banking allies.
Internal suspicious activity reportingEscalation criteria and timelinesManagement and board reporting packsRegulator communication protocolsReporting to sponsor banks and partnersLesson 5Sanctions compliance programme elements: screening workflows, watchlist management, false positive tuning, blocking/filing proceduresThis part elaborates sanctions compliance for payment processors, including screening setup, list oversight, workflow arrangement, false positive minimisation, and steps for blocking, declining, 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 guides on drafting and upholding AML, sanctions, KYC, EDD, monitoring, data protection, and recordkeeping policies and procedures that are risk-oriented, practically feasible, version-managed, and in line with regulatory standards.
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 development by role, training intervals, delivery approaches, completion monitoring, effectiveness testing, and corrective actions for poor performance 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 organisational structure: Board oversight, Compliance Officer responsibilities, escalation pathsThis part outlines governance setups for AML and compliance in payment processors, specifying board supervision roles, the Compliance Officer remit, escalation routes, and committee structures that guarantee autonomous, adequately supported control functions.
Board AML and compliance oversight dutiesCompliance Officer mandate and authorityThree lines of defence 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 clarifies recordkeeping and auditability demands for AML programmes, covering retention timetables, secure archiving, audit trails for critical choices, and change oversight for rules, models, and data to aid regulator and internal audit examinations.
Regulatory record retention requirementsDesigning searchable audit trailsEvidence of investigations and decisionsChange control for rules and modelsData lineage and system-of-record controls
