LEX ARTA
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AML/CFT  ·  Ongoing Support  ·  MLRO Outsourcing

Outsourced MLRO &
AML Compliance Support

Senior-led AML support and outsourced MLRO services for CASPs, crypto businesses, fintech, payment institutions and other regulated businesses that need expert judgment, operational capacity, fractional oversight or a formal AML mandate where permitted.

From AML/CFT framework development and remediation to operational capacity, fractional AML oversight and outsourced MLRO or designated AML Officer mandates where permitted.

Project-based and ongoing support with clearly defined scope, responsibilities, decision rights and deliverables.

No standard onboarding feeSenior-led deliveryProject and monthly modelsEU-focused · Cross-border support
Build
Framework, governance
and workflows
Operate
Senior and operational
monthly capacity
Lead
Fractional or designated
AML function support
AML beyond the policy document

People, Processes, Controls and Accountability.

A credible AML programme requires more than written policies. It requires defined responsibilities, decision authority, workable procedures, trained capacity, documented escalation, reliable management information and evidence that controls operate in practice.

LEX ARTA separates development work from ongoing support so clients can purchase the level of involvement they actually need — without paying for a formal role where expert advice is sufficient, or expecting a limited retainer to operate an entire department.

Choose by outcome
Build the function
Develop or remediate AML/CFT policies, procedures and control documentation.
Design governance, roles, workflows, staffing and reporting.
Implement and launch a functioning AML department.
Run the function
Access senior AML judgment.
Add controlled operational capacity.
Obtain structured fractional oversight or a formal role holder.
Project-based services

Build or Rebuild the AML Function.

The final scope is confirmed after an initial review of the regulated activities, customer model, transaction flows, existing documentation and implementation status.

01 · Framework

AML/CFT Framework Development

From €7,500
Up to 45 senior hours · Indicative delivery 4–6 weeks

For businesses creating an AML/CFT framework from the beginning or materially rebuilding existing documentation and control design as a defined implementation project.

  • AML/CFT policy and governance provisions
  • Customer-risk methodology and acceptance rules
  • CDD, KYB, EDD and beneficial-ownership procedures
  • PEP, sanctions and adverse-media controls
  • Source-of-funds and source-of-wealth requirements
  • Transaction-monitoring and escalation framework
  • Suspicious-activity reporting procedures
  • Record keeping, outsourcing controls and operational registers
  • Management reporting and compliance monitoring requirements
Primary outcome

Agreed policy and procedure package, methodologies, registers, templates and an implementation roadmap. Broader remediation of identified findings is separately scoped where required.

Request Framework Development →
02 · Operating model

AML Function Design & Implementation

From €9,500
Up to 60 senior hours · Indicative delivery 5–8 weeks

For businesses that need a workable AML operating model, whether documentation already exists or is being developed in parallel.

  • AML governance and organisational model
  • MLRO, Deputy, analyst and QA responsibilities
  • Decision, responsibility and escalation matrix
  • Internal, outsourced or hybrid delivery model
  • Staffing and capacity plan
  • Onboarding, review, monitoring and escalation workflows
  • QA, KPI, KRI and management reporting framework
  • Technology and vendor requirements
  • 90-day implementation plan
  • Implementation workshop and role-based training
Primary outcome

Documented operating model, responsibility structure, workflows, capacity plan, reporting pack and implementation roadmap.

Discuss Function Design →
03 · Launch

AML Department Build & Launch

From €18,500
Up to 110 senior hours · Indicative delivery 8–12 weeks

For a regulated business that needs documentation, operating design and practical launch support for a functioning AML department.

  • Framework development and operating-model design
  • Implementation management and department structure
  • Job descriptions and candidate-assessment support
  • Analyst guidance and case-management structure
  • KYC, screening and monitoring vendor support
  • SLA, capacity and productivity framework
  • Sample file, alert and escalation testing
  • Staff, management and board briefing
  • AML-function launch assessment
  • Initial remediation register and post-launch transition plan
Primary outcome

A documented, staffed and tested AML operating structure ready to transition into an internal, fractional or designated model.

Discuss Department Build →
Scope boundary. Independent AML assurance is provided through AML Audit & Compliance Review. A full AML/CFT Enterprise-Wide Risk Assessment, specialist Travel Rule project, historic file remediation, software licences, analysts, recruiters and local regulated role holders are included only where expressly agreed.
Monthly service models

Ongoing Support: From Expert Advice to Outsourced MLRO.

Each model reflects a different level of involvement. The client should choose according to who performs operations, who manages the workplan and who holds formal decision authority.

01 · Expert advice

AML Expert Desk

€1,250 / month
10 senior hours · Extra time €150/hour · Minimum 1 month

For a business with an internal AML lead that needs access to senior external judgment.

  • Complex CDD and EDD matters
  • PEP, sanctions and adverse-media escalations
  • Source-of-funds and source-of-wealth questions
  • Transaction-monitoring and wallet-risk interpretation
  • Policy interpretation and regulatory questions
  • Written advice and Decision & Action Log
Client retains

Management of the AML function, operational processing and all formal statutory responsibilities.

Request Expert Desk →
02 · Operational capacity

AML Operations Capacity

€1,500 / month
15 operational hours · Extra time €120/hour · Minimum 3 months

Controlled overflow, remediation and operational support — not a full outsourced operations centre.

  • KYC and KYB file review
  • Periodic and trigger-event reviews
  • First-level sanctions, PEP and alert triage
  • Missing-document follow-up and case notes
  • Remediation of agreed files
  • Operational tracker, escalation summaries and sample QA
Client retains

Final high-risk acceptance, relationship termination and suspicious-activity decisions unless separately mandated.

Request Operations Capacity →
03 · Structured oversight

Fractional AML Function

€2,400 / month
18 senior hours · Extra time €160/hour · Minimum 3 months

For a business that needs an ongoing senior AML workplan and governance support without transferring the formal role.

  • Monthly AML workplan
  • Oversight of agreed AML controls
  • Review of material escalations
  • Risk-based file or alert sampling
  • Remediation tracking and minor procedure maintenance
  • Regulatory-change assessment
  • Monthly management meeting and Governance Report
Client retains

The formally appointed AML Officer or MLRO role and statutory decisions not expressly delegated.

Discuss Fractional Support →
04 · Formal mandate

Designated AML Officer / MLRO

From €3,250 / month
20 senior hours · Extra time €185/hour · Minimum 6 months

Formal AML leadership where an external appointment is permitted and proportionate to the entity and risk profile.

  • Formal mandate and direct management reporting line
  • AML governance and material escalation oversight
  • High-risk decisions within the agreed authority
  • Internal suspicious-activity review
  • STR/SAR decisions and reporting where assigned
  • FIU or regulator communication within scope
  • Quarterly governance reporting and annual MLRO report
Appointment conditions

Subject to applicable law, regulator expectations, client risk acceptance, conflicts, framework quality and LEX ARTA capacity.

Discuss a Designated Role →
At-a-glance comparison

Choose by Responsibility, Not Only Hours.

ServicePrimary purposeRecurring deliverableOperational processingFormal role
AML Expert DeskSenior advice and second opinionDecision & Action LogNo, except limited case reviewNo
AML Operations CapacityOverflow, file review and remediationEvidence Pack and case trackerYes, within included capacityNo
Fractional AML FunctionStructured workplan, oversight and reportingMonthly Governance ReportLimited; focus is oversightNo
Designated AML Officer / MLROFormal AML leadership and accountabilityDecision log, governance reports and annual reportLimited; operational team remains separateYes, where permitted
Decision boundaries

Clear Allocation of AML Responsibility.

Outsourcing support does not remove the management body’s responsibility for effective AML governance. The engagement documents who performs, reviews, decides and approves each activity.

LEX ARTA may perform or support

  • Document and framework development
  • Operational reviews and escalation preparation
  • Senior case analysis and quality assurance
  • Workplan, remediation and management reporting
  • Formal MLRO decisions where legally assigned under a designated mandate

Not transferred automatically

  • Management-body responsibility for AML governance
  • Commercial acceptance decisions outside the agreed mandate
  • Unlimited operational processing
  • Technology ownership and data quality
  • Activities that applicable law or the regulator requires the client to retain
Who delivers this

Practitioners, Not Template Providers.

AML function support at LEX ARTA is led by senior practitioners who have personally held MLRO, Compliance Officer and DPO roles in regulated businesses — not consultants delivering documentation they have never operated.

Engagements are structured around defined responsibility, documented decisions and evidence that agreed controls operate in practice.

Credentials & background
ACAMS-certified anti-money laundering specialists
CySEC AML certification
Operational experience in MLRO, Compliance Officer and DPO roles
Doctoral-level legal expertise with a focus on regulated business and compliance
Continuity and scale

Additional AML Capacity.

Continuity
Deputy AML Officer / Continuity Cover
From €1,250/month
Six senior hours, agreed deputy or continuity mandate, periodic briefing and cover during defined absence. Extra time €175/hour. Minimum three months.
Temporary role
Interim AML Officer / MLRO
From €3,750/month
Up to 25 senior hours for vacancy, notice-period or transition coverage. Minimum two months. Historic remediation is separately scoped.
One-off support
Ad Hoc Senior AML Support
€175 / started hour
Urgent advice, isolated EDD or sanctions matters, policy questions and management escalations. For businesses without a recurring need — no reserved capacity and no Decision & Action Log; where questions recur monthly, the AML Expert Desk is more economical.
Higher volume
Dedicated Analyst Capacity
Individually scoped
For sustained operational volumes materially beyond the standard capacity package — typically where the workload approaches a part-time or full-time analyst. Scope depends on systems, language, SLA, risk profile, QA and replacement requirements.
Commercial terms

Capacity and Pricing Rules.

No standard onboarding fee
Initial review, access setup, responsibility mapping and workplan preparation use the first month’s included capacity. Material framework remediation or historic backlog is separately scoped.
Time recording
Monthly services are recorded in 15-minute increments. Work beyond included capacity requires approval. Ad hoc support is charged for each started hour.
Unused capacity
Unused monthly hours do not roll over or become refundable. The retainer reserves agreed professional capacity and covers the stated recurring deliverables.
Third-party costs
Software, analysts, local role holders, recruiters, specialist technology input, translations and official costs are excluded unless expressly stated and approved.
Pricing basis
Final pricing depends on regulated activities, risk, volumes, entities, jurisdictions, existing documentation, systems and the expected level of escalation and regulatory interaction.
LEX ARTA fees
Published figures are LEX ARTA professional fees for the stated standard scope. LEX ARTA does not add VAT. Work outside scope is performed only following written approval.
Regulatory context

When Can the AML Function Be Outsourced?

Whether an outsourced MLRO or externally supported AML function is permitted depends on the jurisdiction, the type of authorisation and the specific activity. Some regimes allow an external appointment subject to conditions; others require the role holder to be an employee, a member of management or locally resident. Depending on the applicable regime, outsourcing may also trigger notification, approval, governance, due-diligence, contractual, access, audit or oversight requirements.

As a general governance principle, outsourcing support does not eliminate the management body's responsibility for effective AML governance. Each LEX ARTA engagement therefore documents who performs, who reviews, who decides and who approves before the work begins.

Assessed before any formal appointment
Applicable law and regulator expectations for the entity type
Local presence, residence or employment requirements
Notification or approval obligations for outsourcing
Conflicts of interest and independence constraints
Condition of the existing AML framework and client risk profile
Where a formal appointment is not available or not appropriate, the Fractional AML Function provides structured senior oversight while the statutory role remains with the client.
Engagement process

From Scoping to Working AML Support.

01

Initial scoping

The business, regulatory status, activities, customers, volumes and current AML model are reviewed.

02

Model selection

The appropriate model is identified: framework development, function build, operational capacity, fractional oversight or a formal role.

03

Scope confirmation

Capacity, deliverables, decision rights, exclusions, fee and client dependencies are agreed in writing.

04

Implementation

LEX ARTA completes the project work or establishes the monthly workplan, reporting and escalation process.

05

Review and transition

The service is reviewed against actual workload and can transition as the business becomes authorised, grows or internalises the function.

Frequently asked

Questions About AML Support & MLRO Outsourcing.

Fractional AML Function provides structured senior oversight, workplan management, quality review and reporting while the formal statutory role remains with the client or another appointed person. Designated AML Officer / MLRO includes a formal mandate where permitted and expressly accepted.
Yes. The project may cover policies, methodologies, governance, responsibilities, workflows, staffing, reporting, technology requirements, implementation testing and launch support. The exact scope depends on what already exists and whether third-party staffing or systems are required.
No. The service is sold by operational capacity because case complexity, data quality, customer risk and required follow-up differ. The engagement may set planning assumptions, but not an unconditional case-volume guarantee.
There is no standard separate onboarding fee. Initial review and setup use the first month’s included capacity. Material historic remediation, policy redevelopment or systems work is quoted separately.
No. The appointment depends on applicable law, local presence or residence rules, regulator expectations, the entity and activities, conflicts, client risk acceptance, the condition of the AML framework and LEX ARTA capacity.
Potentially. LEX ARTA may support implementation and preparation during the licensing stage, but the role, deliverables and regulatory status must be accurately described. A formal designated appointment begins only when legally and operationally appropriate.
LEX ARTA does not present a review as independent where it would be evaluating framework elements it recently designed or operated and the conflict cannot be appropriately managed. Independent audit scope is handled separately.
Build the Function. Define the Responsibility. Reserve the Capacity.
Share the current AML setup, regulatory status and areas requiring support. LEX ARTA will confirm the appropriate project or monthly service model and the responsibilities that remain with the client.
Why LEX ARTA

Why LEX ARTA for Outsourced MLRO & AML Support.

Senior AML support is structured around the role the client actually needs — advice, operational capacity, fractional oversight or a formal designated function where permitted.

Senior OversightComplex AML decisions, governance issues and regulatory priorities receive practitioner-level attention.
Defined ResponsibilitiesScope, decision rights, retained client responsibilities and escalation routes are set out clearly for each engagement.
Scalable SupportSupport can move from expert desk or operational capacity to broader fractional oversight as the AML function develops.
Implementation FocusThe work connects policies, risk assessment, controls, training, reporting and evidence rather than treating the MLRO role in isolation.