Case Study — Payments / Risk & Compliance Advisory
A payments firm scaling rapidly across new markets needed its AML controls redesigned, after a pattern of market-by-market patches had left monitoring thresholds that varied for reasons nobody currently at the firm could explain.
The Transformation Framework™
AML controls had been extended market by market through local patches rather than a redesigned framework, with transaction monitoring thresholds that varied for undocumented reasons.
Each market launch had been under time pressure, and control design had consistently lost out to go-live deadlines. Compliance had flagged the pattern for over a year without securing sponsorship to pause expansion long enough to fix it.
Rather than pausing expansion, we designed a parallel remediation track: redesign the two highest-volume existing markets immediately, while building a single global control framework that new markets could launch into directly.
The global framework was built and tested against the two priority markets within four months, with thresholds now derived from a documented risk methodology. Two subsequent launches used the new framework from day one.
False-positive alert rates fell 52% in the remediated markets, freeing analyst time for genuine investigation. The two newest launches required zero framework rework post-launch, against an average of three rounds in prior markets.
Measured Outcomes
Reflection
"A control that varies by market for reasons nobody can explain isn't a control. It's a habit that hasn't been questioned yet."
Nina Kapoor — Head of Risk & Compliance AdvisoryEngagement team
Head of Risk & Compliance Advisory
Principal, Payments
Senior Consultant