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AML/KYC Refresh Ops

A managed service that runs the periodic KYC-refresh queue for small EU fintechs and lenders: case pull, document chase, screening triage, review memos, audit trail.

Possible fit
Category
Agency
Difficulty
Moderate
Revenue potential
Solid
Startup cost
€3k

Executive summary

You can run KYC refresh work for small EU firms that have to keep the decisions themselves but need help clearing their review backlog.

There's a small but real opening here. The new AML rules (AMLR) apply from 10 July 2027, Article 18 makes outsourcing tighter, and the client still has to own the final call and the core risk decisions.

That leaves room for someone to do the grunt work: chasing documents, sorting through screening hits, drafting memos, and packaging everything for audit. This is most useful for small e-money firms, payment firms, crowdfunding platforms, and niche lenders.

This isn't a generic compliance consultancy. You run the operations for them, and you charge by analyst hours and per file reviewed. AI cuts the time each file takes, but a qualified human still signs off.

  • The regulation opens the window, but only for doing the work, not for making the decisions.
  • Being based in the EU, having ACAMS-qualified people, and backing your work with service levels sets you apart from offshore or vague analyst outsourcing.
  • Your best first customers are small firms with heavy compliance loads, a steady backlog of reviews, and no analysts of their own.

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  • Step-by-Step 90-Day GTM Blueprint
  • Editable 3-Year Financial Model (XLSX)
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Questions, answered

What happens when a review hits a risk flag?

We triage the screening hit, extract and check the documents, and draft the review memo, but your team keeps the final risk decision and sign-off.

How do you stay compliant with AMLR Article 18?

The service is scoped to execution only, so accountability, core risk assessment, and policy decisions remain with the obliged entity.

Why wouldn't we just outsource this offshore?

The report says trust is a blocker, so the wedge is EU-timezone, EU-language, GDPR-native delivery with a compliance pedigree and an auditable workflow.