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AML Operations that Stand Up Under Real Regulatory Scrutiny

For online gambling operators: we fix case workflows, EDD/SoF decisioning, and evidence so your AML holds up in audits, renewals, and inspections.

Fix Case Workflows

Reduce inconsistency, rework, and weak investigation handoffs.

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Strengthen Withdrawal EDD/SoF

Make higher-risk decisions clearer and easier to defend under review.

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Make AML Evidence Audit-Ready

Improve case-file quality, narratives, and documentation under review.

Where AML Breaks In Practice

In many cases, the issue is not policy.
It is whether operations can produce defensible evidence under pressure.

Alert Volume Outruns Quality

Investigation quality drops as alert volume rises.

Withdrawal SoF Breaks

Higher-risk decisions break at the point of payout.

Narrative Inconsistency

Similar cases produce different rationales and outcomes.

Weak Case Files

Files do not clearly reconstruct the decision under review.

These are not policy gaps. They are operational failures.
This is where we focus.

AML Operations Capability Areas

Areas where AML operations most often break under growth, and where we help redesign them.
Operating Model

Operating Model & Governance

Operationalize ownership, escalation, and governance so AML decisions stay consistent under scale.

Cross-Functional AML Delivery

Cross-Functional Delivery

Facilitate delivery of AML improvements across Compliance, Product, and Engineering that actually ship and stick.

Operational Controls

Risk Appetite to Operational Controls

Convert risk appetite into thresholds and workflows that drive day-to-day AML decisions.

EDD & Investigations Delivery

EDD, Investigations & QA

Make investigations, SAR rationale, and QA more consistent, repeatable, and defensible.

KYC & OSINT Operations

KYC & OSINT Operations

Improve onboarding, OSINT evidence collection, and refresh workflows without adding unnecessary friction.

Tooling & Automation

Tooling, Automation & Vendor Governance

Improve utilization of existing tools, reduce manual work, and govern tuning, vendors, and change control.

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 ownership so AML decisions stay consistent as volumes rise.

3


Align Systems

Optimize tooling and data flows so controls are enforced through streamlined systems rather than scattered, inconsistent workarounds.

4


Implement

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

Where are your AML operations breaking under growth?

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

Outcomes You Can Expect

Reduced Alert Backlogs

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

Faster Throughput

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

Consistent Decisions

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

Clear Ownership & KPIs

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

Less Manual Work

Utilize your current tooling to its fullest and automate the right steps to eliminate needless work.

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 AML-regulated entities where customer growth, product complexity, and supervisor scrutiny are outpacing AML operations.

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

You are likely experiencing:

  • Manual processes consuming analyst capacity needed for higher-value work
  • 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

iGaming Operators

High-growth online gaming and betting platforms operating across multiple jurisdictions under increasing AML scrutiny.

  • Rapid player growth and escalating alert volumes

  • Fragmented KYC, OSINT, monitoring, and payments tooling

  • Escalations and SAR decisions struggling to scale

  • VIP programs and cross-border payments increasing risk complexity

Crypto-Asset Service Providers

Crypto exchanges, custodians, and other CASPs operating under MiCA and Travel Rule obligations while scaling monitoring and wallet risk controls.

  • On-chain transaction monitoring integrated with AML investigations

  • Travel Rule, sanctions screening, and counterparty risk across wallets

  • Rapid transaction growth driving alert volumes and investigations

  • Increasing scrutiny from MiCA licensing, banking partners, and counterparty due diligence

Fintechs & Payments

Software-first fintechs, PSPs, EMIs, and payments platforms managing complex flows and growing supervisory scrutiny.

  • Multiple products, rails, and jurisdictions increasing monitoring complexity

  • AML embedded across onboarding, payments, and transaction monitoring

  • Growing scrutiny from banks, regulators, and payment partners

  • 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 slowing fixes

  • Upcoming inspections, audits, or market launches

  • Risk scoring or monitoring logic no longer fits 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 patches

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

Operational Experience in High-Growth Regulated Businesses

20+ Years in Software & Technology

Building operational systems in internet-native organizations.

CAMS Certified AML Expertise

Professional certification in global AML standards and practice.

Specialized in AML Operating Models

Focused on monitoring, escalation, and investigation workflows.

Compliance × Product × Engineering

Delivering AML improvements across compliance and engineering teams.

 

Our work focuses on AML operations across iGaming, fintech, payments, and crypto.

Start with a Short AML Ops Diagnostic

Identify the 2–3 operational changes most likely to reduce backlog, friction, or capacity constraints.

Your point of contact
Mike Caha
Mike Caha, MBA, CAMS
Managing Partner, AAYT
 
  • Best suited for teams scaling AML operations
  • Initial calls typically last 30 minutes
  • Leave with a clearer view of bottlenecks and priorities
  • Operational focus, not legal advisory

We usually reply within 1–2 business days.

No sales deck. No generic compliance pitch.

 

Prefer to schedule directly →