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Service

Compliance Outsourcing

Ongoing expert AML support without carrying a full team. We prepare, explain and support; the decision and the signature stay with you.

Fee
Retainer, monthly or quarterly
Volume
Eight to twenty hours a month
Response
Within one business day
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Where the boundary runs

Start with what this service is not, because that is the first question. We do not become your responsible officer in the legal sense and do not take on liability before the regulator. That liability sits with the supervised entity and with the person it appoints, and it cannot be handed to a contractor by contract or by fee.

We take

Ongoing expert support: we prepare documents, give opinions, run processes, train people and answer for the quality of that work.

Stays with you

The decision, the approval of a document, the appointment of the responsible officer, filing reports with the regulator and meeting its requirements.

The split works in your favour too: a professional level of compliance without a full team, while control and accountability stay inside the firm rather than leaving with a contractor.

Three ways of working

Reinforcing an existing team

You have a specialist or a small team, and we act as a second opinion and a safety net: we work through hard cases, check contested decisions and take load at the peaks.

Full operational support

There is no dedicated specialist. We prepare everything and you approve and sign. This suits smaller firms for whom a full team is out of proportion, while the requirements still apply in full.

Not in Kazakhstan

Acting as the responsible officer where that is permitted

Some jurisdictions allow the function to be performed externally. In Kazakhstan that is not the case for supervised entities in the classic sense, so here we work in the first two formats.

What the support covers

  • Tracking changes in the law and regulator guidance, with prompt notice
  • Advice on live questions: customer checks, suspicious activity, risks, regulator requests
  • Help preparing and filing reports with the regulator
  • Support with the risk assessment and with updating internal control rules
  • Inspection preparation and support around dealings with the regulator, without us taking part in the inspection itself
  • Customer checks and risk level assignment
  • Improving how the function works and streamlining processes
  • Staff training on request

How the money and the time work

The work runs on a retainer: a fixed amount per month or per quarter. It includes a set number of hours, usually eight to twenty a month depending on the package and the size of the firm. Anything beyond that is billed separately at an agreed rate.

If the volume is small or unpredictable, other shapes are possible: a package plus additional work, or hourly billing.

The point of a retainer is not the hours. It is that a question can be asked the moment it appears, rather than when a budget for it appears.

Compliance gets expensive precisely because of postponed questions.

What you get

Regular report

Monthly or quarterly. What was done, what changed in the requirements, what we recommend next and by when.

A line that is open

An answer within one business day, urgent questions first. You ask when the question appears.

Taking part in meetings

By arrangement we join internal compliance meetings, including discussions of difficult customers and transactions.

Current templates

Access to working forms and checklists that we keep up to date as the requirements change.

Format and terms

The package is sized by transaction volume and by how many questions come up, not by headcount in the abstract. You can start small and extend it if the load turns out to be higher. No long minimum term.

Frequently asked questions

Will you be our official responsible officer or MLRO?

No. That position sits inside your firm and cannot be handed to a contractor. We make sure the person you appoint performs the role well: we prepare documents, give opinions, run processes and train people.

What if the regulator finds a breach? Who answers?

Liability before the regulator sits with the supervised entity and its responsible officer. We answer for the quality of our work and take part in remediation, but accepting liability on your behalf is impossible under either the contract or the law.

Can compliance be outsourced entirely so we do nothing ourselves?

No, and anyone promising otherwise is selling you a problem. Approving documents, appointing the responsible officer, filing reports and meeting requirements stay with you. We take the work, not the obligation.

What does it cost?

The retainer depends on transaction volume and on how many questions come up, that is, on how many hours a month are needed. We size the package after a conversation about what a typical month looks like for you.

How is this different from one-off consulting?

We keep your context in mind. A one-off consultation starts with explaining who you are and how things work, and half the time goes on that. Under a retainer the question is asked straight on the substance.

Shall we look at your case?

Tell us the task and we will say whether it needs the full piece of work or a narrower one.

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Northhold Advisory is an independent consultancy. We are not affiliated with, and do not represent, the AFM of Kazakhstan, the AIFC (AFSA) or the National Bank of Kazakhstan.

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