Client situation | Regulatory & financial security

Financial Security & Financial Economic Crime

AML/CFT, KYC/CDD, transaction monitoring, transaction filtering and sanctions – made workable across operations, data, tooling and governance.

We help financial institutions translate financial security and financial economic crime obligations into practical delivery plans, clear governance, better data, workable operating models and controlled execution.

Independent, senior and pragmatic support for banks, asset managers, insurers and financial services organizations.

Typical situations where we help

Financial crime obligations become difficult when regulation, operations, data, tooling and capacity constraints start to interact. These are typical situations where Phibonacci can help.

KYC/CDD remediation pressure

Periodic reviews, event-driven reviews or customer data updates have created backlogs, quality issues, audit concerns or unclear ownership.

Transaction monitoring effectiveness

Alert handling, scenario changes, investigation quality, escalation logic or management reporting need to become more controlled and transparent.

Screening, filtering and sanctions controls

Customer screening, payment filtering, sanctions hit handling, PEP/adverse media processes or escalation paths require better evidence and operational consistency.

Operating model, tooling and data change

Policies, processes, roles, data, workflow tooling and reporting need to be translated into a practical model across compliance, operations, IT and business.
Why this becomes difficult

The challenge is not only regulatory. It is operational.

AML and financial security obligations may be clear at policy level, but execution is rarely simple.

Client files, data quality, screening logic, transaction monitoring, case handling, reporting, ownership, tooling and capacity all need to work together. When they do not, institutions face backlogs, audit issues, inconsistent evidence, operational friction and avoidable delivery risk.

Regulatory pressure

Supervisory expectations, AMLA developments and internal control requirements increase the need for clear evidence, consistent execution and demonstrable control.

Operational reality

Teams deal with volumes, exceptions, manual workarounds, unclear handovers and competing priorities while the business still needs to run.

Data and tooling dependency

Monitoring, filtering, screening, workflow and management reporting depend on data that is often fragmented, incomplete or insufficiently governed.

Where Phibonacci adds value

Phibonacci supports financial institutions with senior, focused and pragmatic delivery leadership. We help clarify what is needed, structure the work, align stakeholders and apply the right level of governance, discipline and flexibility — fit for purpose, without unnecessary overhead.

01

AML/KYC remediation needs structure

We translate the challenge into a clear delivery plan, backlog logic, governance rhythm and decision path.

02

Policy is not yet executable

We help bridge policy, process, data, tooling, operations and control evidence.

03

Ownership is fragmented

We clarify roles, dependencies, escalation paths and delivery accountability across compliance, operations, IT and business.

04

Tooling evolution creates uncertainty

We support requirements, process fit, data dependencies, testing, migration and controlled implementation.

05

Management lacks a reliable view

We help define practical management reporting, progress tracking, risk indicators and steering information.

Relevant scope

The exact scope depends on the client situation. These are the areas that typically need to be connected when financial security obligations are translated into workable operations, tooling, data and governance.

Customer due diligence, periodic reviews, event-driven reviews, UBO data, customer risk scoring, PEP handling, client outreach, evidence requirements, quality control and file completeness.

Data completeness, client contact triggers, call-for-action flows, channel integration, client communication, operational follow-up and future-proof extension possibilities.

Alert handling, investigation workflow, scenario changes, escalation logic, backlog management, SAR/STR process support, management reporting and effectiveness tracking.

Customer and payment screening, sanctions hit handling, false positives, PEP/adverse media logic, escalation paths, operational procedures, evidence and control reporting.

Roles and responsibilities, process ownership, control points, decision forums, issue management, remediation planning, stakeholder alignment and BAU handover.

Business requirements, data dependencies, workflow tooling, case management, dashboards, testing, migration, implementation support and operational acceptance.

Current context

Regulatory context is moving. Execution needs to follow.

The EU AML/CFT framework is entering a new phase. Financial institutions need to respond not only with policy updates, but with practical changes in governance, data, processes, tooling, controls and reporting.

New EU AML/CFT framework published

EU-level AML/CFT tasks move from EBA to AMLA

More harmonization, evidence and data-driven oversight

New European AML/CFT framework

The AMLA Regulation, the AML Regulation and the 6th AML/CFT Directive were published in the Official Journal on 19 June 2024. AMLA has had legal existence since 26 June 2024.

EU-level AML/CFT supervision is shifting

From 1 January 2026, responsibility for EU-level AML/CFT tasks moved from the European Banking Authority to AMLA. Existing EBA AML/CFT guidelines remain in force until replaced by AMLA.

Operational impact becomes more visible

The direction of travel is clear: more harmonization, more evidence, stronger supervisory convergence, more data-driven oversight and higher expectations around effective, consistent and explainable controls.

Relevant delivery experience

Phibonacci combines financial services domain knowledge with hands-on delivery leadership across regulatory change, operations, systems, data and complex transformation.

Project proof
Belgian/German retail direct bank
Relevant for KYC/CDD remediation, client outreach, data completeness, digital triggers, stakeholder alignment and future extension of data actualization flows.
Project proof
Belgian branch of a global bank
Relevant for translating regulatory obligations into sustainable governance, evidence, data, roles, responsibilities and operational setup.
Project proof
Belgian retail direct bank
Relevant for AML/KYC-related data migration, systems dependencies, operational continuity, interdependency management and controlled implementation.

Frequently asked questions

A few practical clarifications on AML/CFT, KYC/CDD, transaction monitoring, transaction filtering and sanctions-related change.

KYC and CDD are core building blocks of AML/CFT. Financial institutions need to understand who their customers are, assess their risk profile, keep customer information up to date and ensure that the right controls, evidence and follow-up processes are in place.

Transaction monitoring typically looks for suspicious patterns or behaviour after or around transactions. Transaction filtering is more focused on screening payments or parties against sanctions and other lists before execution or processing. Both depend heavily on data quality, rules, workflows, escalation logic and operational follow-up.

AML/KYC remediation becomes a delivery challenge when backlogs, data quality issues, client outreach, tooling constraints, unclear ownership, audit findings or supervisory pressure start to interact. At that point, the issue is no longer only regulatory. It becomes operational, organizational and data-driven.

Phibonacci does not position itself as a volume-based AML managed service provider. We focus on senior, practical delivery support: structuring the work, aligning stakeholders, managing dependencies, improving governance and helping institutions make financial security change workable and controlled.

Support can include delivery planning, requirements clarification, process design, evidence requirements, operational procedures, escalation paths, testing, reporting and implementation coordination across compliance, operations, technology and business stakeholders.

Share this page with a colleague

Need to make AML/KYC, monitoring or sanctions change workable?

Phibonacci can help structure the situation, identify the main delivery risks and define a practical way forward before the work becomes too large, too slow or too fragmented.

Tip: filter by “Financial Economic Crime” expertise on the track record page to view related projects.

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