Partner Bank AML Requirements
A partner bank runs its own exam, and it is not the regulator's. The bank looks at your system from its own side of the risk and decides whether to open the account, keep serving you, or close it.
- Duration
- One to three weeks
- Format
- Remote
- Result
- Answers to the bank, compliance pack and evidence
When this work is needed
There are usually three triggers, and they arrive in very different moods.
- Calm
Opening an account or onboarding
The compliance team at a bank or payment provider has sent a questionnaire and a document list.
- Scheduled
Relationship review
Your existing bank asks for updated documents and explanations of your transactions.
- Urgent
A request with warning signs
The bank has already limited transactions or warned that the account may be closed.
What separates these cases is not the quality of the documents but the time left to answer.
What the bank actually looks at
A bank checks not only that documents exist but whether what they describe happens in practice. A typical request covers:
- The anti money laundering questionnaire
- The set of policies and procedures
- Beneficial owners and the ownership structure
- The business model and the flow of funds
- Customer due diligence, sanctions screening and transaction monitoring
- Who owns compliance, who they report to, and what happens when a transaction looks suspicious
Documents are often followed by a video call with the bank's compliance team. On that call the firm presents its business model and control system and answers questions, sometimes with a deck.
How the work runs
First we go through the request itself and the deadline, then we look at what you already have, and only then decide what to write.
- The partner's request is broken down point by point, with an assessment of what is covered and what is not.
- Documents are prepared or reworked to match the partner's expectations, in English where that is required.
- Evidence is assembled for the procedures that are in force.
- Your people are prepared for the interview with the bank.
- The questionnaire answers and the cover letter are drafted, and the correspondence is supported until the questions are closed.
If it turns out along the way that the problem is not the paperwork but the system itself, we say so plainly and show what scope of work would close the gap.
What we do not promise
The decision belongs to the bank and cannot be influenced directly. We answer for the quality and completeness of what you submit, for how truthfully the answers describe your firm, and for the speed of preparation.
Promising an open account or lifted restrictions would be untrue.
The second honest caveat is about content. We do not describe procedures you do not have. If the bank asks about monitoring and there is no monitoring, there is only one way out, and it is to build it.
What you get
Completed partner questionnaire
Answers to the bank or payment provider that match how your firm actually operates.
Compliance pack
Policies, procedures and annexes in the form and the language the partner expects.
Evidence base
Proof that the procedures are carried out, not only written down.
Gap closure plan
A list of what the partner expects to see and you do not yet have, with dates and an order of work.
Timing
That range assumes you have a working set of documents that needs to be aligned with the partner's request. If there is no such set and the system has to be built, the timeline is estimated separately, and we say so at the start.
Frequently asked questions
How is this different from preparing for a regulatory inspection?
An inspector looks at compliance with the law; a bank looks at its own risk from working with you. The documents overlap in part, the emphasis and the wording do not.
Our transactions are already restricted. Is it too late?
It is not too late, but the task changes. First we work out what exactly raised the questions and answer on the substance; rebuilding the system is planned once the conversation with the bank is back on a working footing.
Do we need the pack in English?
Usually yes, if the partner sits outside Kazakhstan. We prepare the documents in the language the partner's compliance team asks for.
Will you talk to the bank instead of us?
No. The correspondence and the calls are led by the firm itself. We prepare the material and the wording, work through every question, and get your people ready for the conversation.
What does it cost?
The fee depends on the scope of the request, on whether current documents exist and on the deadline. We name an exact figure after a short conversation and fix the scope in the engagement terms.
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.
Book a consultation