An AML retainer sized to the firm — not the brochure.
Three tiers, calibrated to firm maturity. Foundations supports an in-house programme that does not yet need full-time senior MLRO bandwidth. Uplift hardens a programme against the next regulator dialogue. Engagement is senior practitioner bandwidth for matters where the cost of getting it wrong is regulator-defining.
3
Tiers, calibrated to firm maturity
1 BD
Response window on a Dear CEO letter
10 BD
Kickoff from signed engagement letter
UK + EEA
Primary jurisdictional coverage
Three tiers.
One firm, one fit.
The right tier is determined by where the firm is — not where the brochure says it should be. Most relationships start in Foundations or Uplift and move tier as the firm changes shape.
Foundations
Who it’s for
Pre-launch VASPs, recently-authorised PIs and EMIs, sub-£10m revenue firms
Practical positioning
“Support layer for an in-house programme that does not yet need full-time senior MLRO bandwidth.”
Uplift
Who it’s for
Firms in transformation — post-supervisory dialogue, post-acquisition integration, scaling into new jurisdictions
Practical positioning
“Structured remediation programme that hardens the firm against the next regulator dialogue.”
Engagement
Who it’s for
Firms in or anticipating active supervisory engagement (FCA s.166 / equivalent NCA inspections), pre-M&A AML diligence, complex SAR / sanctions investigations
Practical positioning
“Senior practitioner bandwidth for matters where the cost of getting it wrong is regulator-defining.”
What is in scope
at each tier.
Each tier carries a documented scope. Anything outside the scope is run as an addendum engagement or a separate workstream — never absorbed silently.
Foundations
- Fractional MLRO support (named, but not sole-control)
- Monthly programme review against your risk taxonomy
- Quarterly board AML pack — narrative, metrics, watch-items
- Ad-hoc questions during business hours
- Annual EWRA refresh participation
Uplift
- Gap analysis vs current EBA Risk Factors Guidelines + applicable national transposition + relevant FATF Recommendations
- Policy and procedure uplift mapped to identified gaps
- Embed support — workshops, training, control owners onboarded
- Quarterly assurance reviews thereafter
- Allowance for supervisory correspondence response within scope
Engagement
- Regulator-dialogue preparation — narrative, evidence file, witness prep
- RFI / s.166 / equivalent response support
- Board attendance for AML committee or risk committee matters
- Technical advisory on complex AMLR, MiCA, and sanctions matters
- On-call availability calibrated to matter urgency
What is out of scope
Three things we will not absorb silently into a retainer.
A retainer that quietly swallows everything stops being useful. We name three categories of work that sit outside retainer scope on principle — and we route you to the right team or counsel when they come up.
Transaction-monitoring system build-out
Vendor selection, rule engineering, and TM platform implementation is a specialist discipline handled under a separate engagement model — not retainer scope.
Licensing applications
New-licence applications (VASP, CASP, EMI, PI authorisations) run through our Banking and Compliance teams under a project engagement letter, not the retainer.
Litigation defence
Where a matter becomes contentious, defence sits with external counsel. We coordinate with counsel; we do not displace them.
Indicative pricing
anchors.
Pricing is shown as anchor — the floor we typically start from. Final scope is priced after the structured intake call, reflecting matter complexity, firm maturity, and on-call availability requirements.
Tier 01
Foundations
From £3,500 / month
scope-priced
Tier 02
Uplift
From £18,000 initial + from £3,000 / month
scope-priced
Tier 03
Engagement
Scope-priced
day-rate framing
Final scope priced after a structured intake call. Pricing reflects matter complexity, firm maturity, and on-call availability requirements. No upper bound is shown publicly — Engagement-tier matters are matter-dependent and quoted in writing.
How an engagement starts.
Four steps, defined timelines, no obligation until the engagement letter is signed.
Intake call
A short structured conversation: licence type, jurisdiction, current MLRO arrangement, the matter or driver bringing you to us. We confirm whether a retainer is the right shape of engagement.
Scoping note
A written scoping note: recommended tier, scope boundary, indicative engagement letter terms, indicative pricing band. You can take it to your CFO and your board without commitment.
Engagement letter + DPA
Engagement letter, professional indemnity disclosure, and Data Processing Agreement. Standard turn — most clients sign within a week of receiving the scoping note.
Kickoff
Named contacts, document index request, calendar cadence set, first deliverable scheduled. Foundations and Uplift kickoffs follow a documented protocol; Engagement-tier kickoffs are paced to the matter.
Questions firms
ask first.
Direct answers to the seven questions general counsel and CCOs raise before signing an AML retainer.
Ready to scope a
retainer the right size?
The intake call is a 30-minute structured conversation. We discuss licence type, jurisdiction, current MLRO arrangement, and the matter or driver. You leave the call with a tier recommendation and a clear next step — whether or not finconduit is the right counterparty.
- Free 30-minute intake call
- Written scoping note within 5 business days
- Engagement letter + DPA on request — no obligation
- Kickoff within 10 business days of signature
Book an intake call
Submit the assessment form and a member of our regulatory advisory team will be in touch within one business day to schedule the intake call.
Go to Assessment FormNot ready for an intake call? Read the FAQ first