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Scaling AML Operations for
High-Growth iGaming & Fintech

Hands-on support for MLROs and AML operators to redesign fragmented, manual workflows so controls scale with growth and stay defensible and inspection-ready.
Solve AML Operations Challenges

Fix Fragmented AML Operations

Redesign alerts, cases, escalation, and data flows so decisions are structured, repeatable, and built to scale under growth.

AML Operations Growth

Scale AML Under Rising Volumes

Ensure monitoring thresholds, CDD, and escalation models absorb rapid growth without burdensome backlogs or sacrificing decision quality.

Inspection-Ready Controls

Build Inspection-Ready Controls

Move beyond fragmented procedures to streamlined controls that are auditable, explainable, and defensible under supervisory scrutiny.

AML programs do not break at the policy level.

They break when growth stress-tests workflows, tooling, and escalation paths that were never engineered to scale.

Mike Caha
Mike Caha, MBA, CAMS
Managing Partner

AML Operations That Stays Durable As You Scale

We turn AML intent into executable workflows, tooling, and evidence so decisions hold up under volume, licensing, and partner review.
Operating Model

Operating Model & Governance

Make decisions consistent under scale. Clarify ownership, escalation triggers, and review layers so outcomes stay traceable and defensible.

Cross-Functional AML Delivery

Cross-Functional AML Delivery

Get changes shipped, not just designed. Align Compliance, Product, and Engineering so AML improvements are implemented, adopted, and measured.

Operational Controls

Risk Appetite to Operational Controls

Turn leadership intent into day-to-day behavior. Convert risk appetite into thresholds, workflows, and tooling rules that guide monitoring, EDD, and escalation.

EDD & Investigations Delivery

EDD, Investigations, SAR/STR & QA

Standardize investigations and evidence. Make EDD depth, SAR/STR rationale, and QA repeatable so files hold up months later.

KYC & OSINT Operations

KYC & OSINT Operations

Speed up onboarding without weakening controls. Standardize OSINT evidence and move to trigger-based refresh so KYC stays clean as volume grows.

Tooling & Automation

Tooling, Automation & Vendor Governance

Reduce tool sprawl and manual work. Run vendors with KPIs + change control so performance does not drift and evidence stays connected.

How Engagements Work

Engagements focus on operational reality, not policy rewrites, 
turning AML policies into scalable, measurable execution.
1


Diagnose

Identify alert quality, backlog pressure, escalation design, workflow friction, and operational bottlenecks.

2


Redesign

Reengineer workflows, escalation logic, and decision ownership so AML operations scale with growth.

3


Align Systems

Align monitoring, case tooling, and data flows so controls are enforced in streamlined tools, instead of scattered and inconsistent.

4


Implement

Ship changes with QA, metrics, and change control so improvements stick as products and volumes evolve.

Where do AML operations break under growth?

A short diagnostic typically identifies the 2–3 changes that remove the most operational friction.

Outcomes You Can Expect

Assess AML Compliance Posture

Reduced Alert Backlogs

Higher signal-to-noise and smarter routing prevent volumes from creating investigation queues.

Assess AML Compliance Posture

Faster Throughput

Less workflow friction and fewer handoffs, so cycle times stay stable as volume grows.

Assess AML Compliance Posture

Consistent Decisions

Clear STR/SAR triggers, rationale, and QA for repeatability and audit-ready.

Assess AML Compliance Posture

Clear Ownership & KPIs

Decision rights and measurable performance across monitoring, EDD, and escalation.

Assess AML Compliance Posture

Less Manual Work

Use your current stack to its fullest and automate the right steps to eliminate repetitive toil.

Assess AML Compliance Posture

Evidence-Ready Data

Better data quality, traceability, and evidence retention so controls stand up to audit, licensing, and partner reviews.

 

Designed for MLROs who need AML operations that stay consistent under growth, audit, and supervisory scrutiny.

 

Who This Is Built For

Tech-led obliged entities where customer growth, product complexity, and regulatory scrutiny are outpacing AML operations.

Organizations that need scalable, defensible AML operations without slowing product velocity or endlessly adding analysts.

You are likely experiencing:

  • Alert volumes and case backlogs growing faster than teams can handle
  • Fragmented tooling across KYC, monitoring, investigations, and payments
  • Escalations or SAR decisions that rely on individual judgment
  • Increasing scrutiny from regulators, banks, or partners
  • Engineering and compliance misalignment slowing operational fixes

iGaming Operators

High-growth online gaming and betting businesses operating across multiple jurisdictions with increasing AML scrutiny.

  • Rapid player growth and escalating alert volumes

  • Fragmented KYC, OSINT, and monitoring tooling

  • Escalations and SAR decisions that struggle to scale

  • VIP programs and cross-border payments increasing risk complexity

Fintechs & Payments

Software-first fintechs and PSP-adjacent platforms with complex flows, partners, and supervisory exposure.

  • Multiple products, rails, and jurisdictions

  • AML embedded across onboarding, payments, and monitoring

  • Pressure from banks, partners, or supervisors to mature controls

  • Monitoring and fraud signals spread across multiple systems

Scale-Ups Under Regulatory Pressure

Companies where AML once worked “well enough” but is now breaking under growth or expansion.

  • Case backlogs and manual workarounds emerging

  • Engineering and compliance misalignment

  • Upcoming inspections, audits, or market launches

  • Risk scoring or monitoring logic no longer matches product complexity

When We Are a Good Fit

You are an obliged entity with real AML risk, meaningful operational volume, and the mandate to fix structural problems properly.

  • Tech-led, software-centric operating model

  • Willing to invest in scalable fixes rather than short-term patches

  • Need hands-on support across compliance, product, and engineering

Fixing AML Operations That Break Under Growth

Regulatory Insight

Regulatory
Insight

Operational Practicality

Operational
Practicality

Proportionate, Defensible Controls

Proportionate,
Defensible Controls

AAYT is a boutique AML Ops advisory focused on fixing and scaling AML operations in high-growth iGaming and fintech companies.

We work hands-on with MLROs, compliance leaders, and legal and operations teams to design workflows and controls that actually function under real-world growth.

Get Hands-On Help Fixing AML Ops at Scale

Use this form to request an AML Ops diagnostic or book a short working session to discuss your biggest operational bottlenecks.
Mike Caha
Mike Caha, MBA, CAMS
Managing Partner
AML Ops Scaling for Tech-Led Companies