From nothing, licensed across borders, with AI doing the gathering and people doing the judgement.
Cross-border payments across Africa, the UK and Canada. Building the risk and compliance function up from close to nothing, with a small team. Licensing included, which takes longer than anyone expects.
Dubai · 2025—A function where there isn't one. Framework, controls, operating model, people, while the product is already live and taking customers.
Four so farRegulated in more than one place at once. Applications, supervisors, board attestation, and the awkward questions before the regulator asks them.
UK · EU · UAE · US · Africa · CanadaPointed at the gathering, never the judgement. Done properly it takes cost out and lifts quality at the same time.
40%+ efficiency gainAI is very good at the first part. Nowhere near the second.
Big teams did that, I was one part of it. I've also been the whole function alone at a startup. Most guidance is quietly written for the first case.
First job, payments officer. Something looked wrong and I had no idea why.
I took it to someone senior expecting to be told I was wasting his time. I wasn't. That was the moment this stopped being a job about forms.
Since then it's been KYC, transaction monitoring and AML risk, then MLRO, head of financial crime, and head of risk and compliance. Investment banks, commercial banks, asset managers, and latterly fintechs.
Somewhere in the middle the job changed. It stopped being about working files and became about designing the thing that works the files, getting it licensed wherever the business wants to operate, and deciding what a team of nine should be doing that a team of ninety used to do.
That is the work now. Build it, license it, and make it scale without it becoming the reason nothing ships.
Banks, asset managers, fintechs. UK, EU, UAE, Africa, North America. Regulators including the FCA, CBUAE, FINTRAC, BaFin-aligned regimes, COBAC and BCEAO.
Under two hours a week. If it takes longer, your scope is too wide.
The week's regulator output, one page. The model gathers, a human tiers. Full spec, copy it and change it.
Read the spec →KYB Triage reads a corporate pack, builds the ownership chain and tells you exactly what's missing from it. Runs locally so nothing leaves the laptop. It won't rate risk or approve anything, and that's on purpose.
Fuzzy-Match lets you throw the transliterations and reversed name orders that actually break screening at your own threshold, and see what 85% catches that 92% doesn't.
First 90 Days is the list of awkward questions that are much easier to ask in week one than in month six.
Document matrix, a worked file, a threshold sandbox, and what actually gets you promoted.
Open → Interactive mapThirty components across three lines, governance and the enablers underneath. Click any one for who owns it, day one against at scale, and how it fails. Twenty five you need from the start. Five can wait.
Open the map →One on the whole operating model. One on the free KYC course. Both under forty seconds.
Governance on top, three lines holding it up, enablers underneath. Thirty components, and only five of them can wait until after day one.
Open the interactive map →Thresholds you move yourself, a document hunt, an ownership chain you unpick. Five modules, no sign-up, no email.
Three posts and one video a week. Where AI actually helps, rather than just sounding good.
Compliance should not be the reason nothing ships. A function that can only say no has failed at its job. The work is building one that can say yes quickly, for the right things, and evidence why.
If nobody owns it, it isn't a control. Pick one at random and ask who gets the call at 11pm. More than five seconds to answer and what you have is documentation.
Automate the triage, never the judgement. Most AI disappointment in this field comes from pointing it at the 20% instead of the 80%.
Design for the licence you want next. Retrofitting a framework for a new jurisdiction costs far more than building it to stretch in the first place.
Standing up a function, chasing a licence, or you think one of my specs is wrong. The useful messages tell me what broke.