The second line of defence, built and run for regulated finance.

We design, operate and evidence AML/CFT compliance for payment institutions, e-money institutions and crypto-asset service providers, to the standard that supervisors, auditors and banking partners test against.

Built to
  • EU AML Regulation
  • MiCA
  • Transfer of Funds Regulation
  • FATF Recommendations
  • Greek Law 4557/2018

Compliance that holds up when it is tested.

Supervisory inspections, bank due diligence and audits all ask the same question: can you show that your controls work? We build programmes that answer it.

  • Clear ownership

    Every obligation has a named owner and a control.

  • Daily operation

    Controls run every day, not only on paper.

  • Full evidence

    Every decision is recorded, ready for a supervisor, an auditor or a bank.

When firms call us

Most engagements begin at one of these moments.

  • Licensing and registration

    We prepare the AML/CFT parts of applications for crypto-asset service providers, payment institutions and e-money institutions, and answer the supervisor's questions until authorisation.

  • Supervisory and audit findings

    We turn inspection findings and audit points into a remediation plan, and produce the evidence that closes each one.

  • Bank and partner due diligence

    We complete due-diligence questionnaires from banks, e-money institutions and payment partners, and keep the evidence ready for the next request.

  • A gap in the compliance function

    When an MLRO or compliance officer leaves, we provide interim cover so that statutory duties continue without interruption.

  • New products, markets and rules

    We assess financial crime risk before launch and adapt controls to the EU AML Regulation, the travel rule and MiCA.

Services

We build the programme, run the second line and prove that it works. Each service stands alone or combines into one engagement.

Build

Design the programme

  • AML/CFT framework

    Business-wide risk assessment, risk appetite, policies, procedures and governance, with training for boards and staff.

  • Customer due diligence

    KYC and KYB onboarding, customer risk scoring, enhanced due diligence and periodic review.

  • Monitoring and screening

    Transaction-monitoring scenarios and thresholds, sanctions screening, tuning, and travel-rule controls for crypto-asset transfers.

Run

Operate the second line

  • Outsourced MLRO

    Where the applicable regime permits it: decisions on suspicious activity, reporting to the Financial Intelligence Unit, oversight of controls, and reporting to the board and the supervisor.

  • Interim cover

    Fixed-term MLRO or compliance officer cover during a vacancy, a licence application or a remediation programme.

  • Operations oversight

    Quality assurance of alert and case handling, management information and compliance reporting.

Assure

Prove that it works

  • Regulatory engagement

    Licence and registration applications, correspondence with the supervisor, and inspection readiness.

  • Independent reviews

    Testing of control effectiveness, transaction look-backs and validation of remediation.

  • Investigations

    Forensic reviews of specific cases, including tracing of crypto-asset flows.

How an engagement runs

Every engagement is agreed in writing, with its scope and deliverables defined in advance.

  1. 01

    Diagnose

    A gap assessment against the rules that apply to you and your actual risk profile.

  2. 02

    Design

    Framework, controls and procedures sized to the business.

  3. 03

    Operate

    We run the function, or support the team that runs it.

  4. 04

    Evidence

    Testing, management information and records, ready for supervisors and partners.

Engagement models

Choose the model that fits the moment. Models can change as the business grows.

  • Retained

    An ongoing function on a monthly basis.

  • Interim

    Fixed-term cover.

  • Project

    A defined scope with defined deliverables.

Who we work with

  • Payment institutions and e-money institutions
  • Crypto-asset service providers
  • Banks and fintech platforms
  • Firms preparing a licence application

Regulatory frame

  • Regulation (EU) 2024/1624EU AML Regulation
  • AML Directives and national lawIncluding Greek Law 4557/2018
  • Regulation (EU) 2023/1113Information accompanying transfers of funds and crypto-assets
  • Regulation (EU) 2023/1114Markets in crypto-assets (MiCA)
  • SanctionsEU and UN restrictive measures
  • FATF RecommendationsInternational AML/CFT standards

Independence and scope

VAP Advisory is a consultancy firm. It does not manage third‑party assets and does not provide financial, crypto‑asset or legal services.

Company

Company particulars

Legal name
VAP ADVISORY SINGLE MEMBER P.C.VAP ADVISORY ΜΟΝΟΠΡΟΣΩΠΗ Ι.Κ.Ε.
Legal form
Single-member private company (I.K.E.) under Greek law
G.E.MI. number
197029804000
VAT number
EL803444257
Registered seat
Vasilissis Olgas 83, 54642 Thessaloniki, Greece

Contact

Email us a short description of your firm and what you need.

admin@vapadvisory.com