Independent AML Challenge
A senior external challenge of your AML framework, decisions and control environment — without replacing your AML function or internal audit.
- 5 business days
- Founder-led senior review
- 90-minute challenge session
- Written management-ready report
A fixed-scope, independent senior AML challenge — an external second opinion that helps management and the AML function identify weak assumptions, material gaps and issues insiders may not see, before board, internal audit or regulatory scrutiny.
It is not internal audit, legal advice, outsourced AML, regulatory certification or approval, and it does not conclude that a firm is fully AML compliant.
Built to strengthen your AML function
CEO / Executive Management
Independent comfort on material AML exposure, management oversight and remediation priorities.
Formally appointed AML responsible person
External challenge supporting documented management oversight and accountability.
Head of AML / Compliance
A senior peer challenge that strengthens your function — it does not bypass, replace or audit your role.
The client remains fully responsible for AML decisions, governance and regulatory compliance.
What we challenge
A focused review of the areas where senior judgement, governance and regulatory defensibility matter most.
Governance & risk
Does the enterprise AML risk assessment actually drive controls, risk appetite, priorities and management decisions?
CDD & higher-risk relationships
Is there a defensible link between identified risk, evidence obtained, enhanced due diligence, residual risk and the final decision?
Monitoring & escalation
Are the documented monitoring and escalation principles coherent with the firm's actual risk exposure and operating model?
Management oversight
Could management explain why it believes the AML framework is effective — not merely demonstrate that policies exist?
What we normally review
- Enterprise-wide AML risk assessment
- Core AML policies and procedures
- Latest AML / Compliance / MLRO reporting to management or board
- Major open findings and remediation status
- Selected supporting evidence or anonymised cases where useful
The exact scope is agreed before the review starts.
- 01Agree the scope
Secure handover of the agreed documents and selected supporting evidence.
- 02Senior AML challenge
AIRI reviews the material from a senior practitioner and regulatory-defensibility perspective.
- 0390-minute challenge session
Structured discussion with the Head of AML / Compliance and, where relevant, the formally appointed AML responsible person.
- 04Management-ready output
Concise written findings, challenge points, priority actions and questions management should be able to answer.
What you receive
A concise, decision-ready output designed for AML, management and board use.
Our overall view of the AML control position within the agreed scope.
The issues an experienced external AML reviewer would challenge first.
Clear recommendations on what should be addressed now, next and later.
The questions the CEO, board or formally appointed AML responsible person should be able to answer.
Direct discussion with your Head of AML / Compliance.
Concise enough to be used — not a 70-page consulting document.
Senior AML judgement — not another generic compliance review
The Independent AML Challenge is led by Andréas Hobbelin, founder of AI Risk Intelligence AS.
- 20 years in AML and financial crime prevention
- Experience across banking, payments, fintech, investigations and regulatory environments
- Operational AML leadership and implementation experience
- Experience from both first-line and second-line AML environments
- Nordic and EU AML perspective
- Human-led assessment supported by AI-enabled analysis where it improves efficiency, structure and coverage
Human-first, AI-enabled
Senior human judgement remains at the centre of every conclusion. AIRI uses AI-assisted workflows where they improve speed, consistency and analytical coverage — but findings, challenge points and conclusions are reviewed and determined by an experienced AML practitioner.
Independent AML Challenge
- Defined scope
- Senior founder-led review
- 90-minute challenge session
- Written management-ready report
- No open-ended hourly billing
Scope-limited independent professional assessment. Not internal audit, legal advice, regulatory certification or regulatory approval.
Independent AML Challenge — questions
Is this an internal audit?
No. The Independent AML Challenge is a focused external professional assessment and senior challenge. It does not replace internal audit or provide statutory assurance.
Does AIRI take over responsibility from our Head of AML or MLRO?
No. The existing AML function retains ownership and decision-making responsibility. AIRI provides an external senior perspective designed to support and strengthen the existing function.
Is this a regulatory certification or approval?
No. AIRI does not certify AML compliance or provide regulatory approval.
Do we need to share customer data?
Not necessarily. The core review can largely be performed using governance documents, policies, reporting, findings and anonymised supporting evidence. Any case-level information required is agreed in advance and handled securely.
Who is the service designed for?
Primarily payment institutions, EMIs, fintechs, crypto/CASP firms and other regulated non-bank financial businesses with lean AML and Compliance teams.
What happens if you identify larger issues?
The report will prioritise the findings and recommended actions. Any follow-up remediation support or deeper review is separately scoped and only performed if requested.
Facing an inspection, licence event or major remediation programme?
The Independent AML Challenge can be used as a first step. Where a broader review is required, AIRI can perform a deeper AML Inspection Readiness engagement covering agreed areas such as governance, CDD/EDD, monitoring, screening, escalation and remediation.
Scope and pricing agreed separately.