Independent Review & Benchmarking

We have personally guided several of our clients through FSA-audits in the past. We know the regulations, the agencies that enforce them and how they operate. We are, in other words, uniquely positioned to help you both achieve and maintain AML compliance.

Sebastian Nordli
Managing Partner


In the realm of Anti-Money Laundering, effective governance is not just a concept, but a necessity. At Frank Penny, we don’t base our approach to governance on hypothetical theories but on experience and what works in the real world. We’ve witnessed first hand what works and what doesn’t, at the various organizations we’ve worked with over the years. A target operating model is only as good as the real world results it delivers.

GAP Analysis

Traditional GAP analyses often fall short, offering broad, generalized insights that lack actionable guidance. Frank Penny adopts a different approach. We delve into the specifics with a hands-on, detail-oriented methodology. Our GAP analyses go beyond surface-level evaluations to uncover the nuances and finer points where critical compliance gaps often lurk. We are committed to being solution-oriented from the onset.

Independent Review & Due Diligence

We provide our diverse set of clients with independent assurance, varying in both magnitude and complexity. No matter the scope, our focus is on delivering valuable insights that help bridge any regulatory gaps. The end product is always customized to the size and circumstances of each clients unique situation.


Effective reporting on ML/TF and compliance risks to the board and senior management is more than a regulatory formality; it's a critical function that many institutions struggle to perform adequately. We can help you establish well-considered KRIs and KPIs that are adapted to your institutions risk tolerance/appetite. Thereby helping you paint the picture on the risks your institutions is exposed to, ensuring that your board and senior management are well-informed and prepared.

Policies & Governing Documents

While drafting governing documents within AML is a service we provide, it's not the core of what we do. At Frank Penny, our expertise lies in tackling complex, hands-on tasks. Any governing document we create is part of a broader solution, tailored to meet regulatory standards and incorporate industry best practices. We steer clear of generic templates, ensuring that our documents are as unique and specific as the needs they address.

Independent Review & Benchmarking

Case Study

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