Compliance-as-a-service: the compliance function on a subscription
You are an obliged entity, but too small for a compliance officer of your own. So it slips — until a supervisor calls. We take over the execution for a fixed monthly fee: policy current, files tested, questions answered, and reporting that shows where you stand.
What it is
Compliance-as-a-service means outsourcing the compliance function on a subscription basis. For a fixed monthly fee your policies and risk assessment stay current, your files are tested periodically, you have a named contact for the day-to-day judgement calls, and you receive reporting that shows where you stand. You keep the responsibility; we supply the expertise, the execution and the second pair of eyes.
The problem it solves
A practice with fifteen people is as much a gatekeeper as a bank with fifteen thousand. The obligations are largely identical: risk assessment, client acceptance policy, customer due diligence, monitoring, reporting, training, and demonstrable oversight of all of it. There is simply nobody whose job that is.
In practice it lands with a partner or the office manager. That works for years, until it does not — and then the policy turns out to date from 2021, the risk assessment is a template, and nobody can point to who decided what.
The core issue: this is not a knowledge problem but a capacity problem. The rules are manageable; keeping up with them alongside a full workload is not.
Three packages
| What you get | Basic from € 395 pm | Active from € 795 pm | Full from € 1,450 pm |
|---|---|---|---|
| Policy and procedures kept current | ✓ | ✓ | ✓ |
| Risk assessment drafted and reviewed annually | ✓ | ✓ | ✓ |
| Helpline for day-to-day questions | Email, answer within one business day | Email and phone | Unlimited, including live case discussion |
| Reporting for management or partners | Quarterly | Quarterly | Monthly |
| File review under four-eyes control | — | Monthly sample | Monthly, plus all high-risk files |
| Support with reports to FIU-the-Netherlands | — | ✓ | ✓, including drafting the report |
| Staff training | — | Annual, one session | Twice yearly, plus onboarding for new staff |
| Formally appointed compliance officer or MLRO | — | — | ✓ |
| Support during a supervisory examination | Day rate | Day rate | Included |
All amounts exclude VAT. The initial term is six months — the first months go mainly into putting what exists in order. After that, two months' notice applies, or three months where our advisor is the formally appointed compliance officer.
What stays with you, and what we do
With you
- The client relationship and the client conversation
- The decision to accept a client or not
- Legal responsibility — that is not transferable
- Providing files and information
With us
- Keeping policy, procedures and risk assessment current
- Testing whether practice follows policy
- Assessing judgement calls and escalations
- Translating new regulation into your situation
- Reporting, so you can steer and demonstrate
How we differ
- Not a software vendor. We sell no platform and take no vendor fees. If you already run an AML system, we work inside it; if you work with spreadsheets, you will hear honestly when that is enough and when it is not.
- MLRO level, not a helpdesk. Your point of contact is Tarik Binnekade, senior advisor and MLRO, who carried the role at regulated institutions in the Netherlands, France and Poland and has been through supervisory examinations from the inside.
- We can carry the role formally. In the Full package our advisor is appointed as compliance officer or MLRO — something a software provider with a service layer cannot offer.
- We say when you do not need us. If the intake shows a half-day of training and a cleaned-up policy is enough, that is the advice you get.
Not the same as interim
Both fill a capacity gap, differently. Interim MLRO and secondment is temporary and intensive: two to five days a week, during a vacancy, a licence application or a remediation programme. Compliance-as-a-service is continuous and light: a fixed rhythm aimed at continuity. If you are unsure which fits, that is exactly what the intake answers.
Frequently asked questions
What is compliance-as-a-service?
Compliance-as-a-service means outsourcing the compliance function on a subscription basis: a fixed monthly fee that keeps your policies and risk assessment current, has your files tested periodically, gives you a named point of contact for day-to-day questions, and produces reporting you can put in front of a supervisor. You keep the responsibility; we supply the expertise, the execution and the second pair of eyes.
Who is it for?
Organisations that are obliged entities under the Dutch AML Act but too small for a compliance officer of their own: notaries, accountancy and bookkeeping practices, tax advisors, estate agents, smaller payment institutions, trust offices and crypto-asset service providers in build-up. Typically firms with five to a hundred staff.
How does it differ from an interim compliance officer?
An interim compliance officer joins you temporarily and often several days a week — during a vacancy, a licence application or a remediation programme. Compliance-as-a-service is continuous and far lighter: a fixed number of hours a month spread across the year, aimed at continuity rather than surge capacity.
What does it cost?
Three packages: Basic from € 395 a month for policy, risk assessment and a helpline; Active from € 795 a month adding monthly file review and reporting support; and Full from € 1,450 a month, including a formally appointed compliance officer or MLRO and support during supervisory examinations. All excluding VAT.
Do you take over our responsibility?
No, and no one can. Legal responsibility rests with your institution and its day-to-day policymakers; that is not transferable. What is possible: our advisor is formally appointed as your compliance officer or MLRO and carries that role in full — while the institution remains accountable. Any provider claiming to assume your liability is selling something that does not exist.
Are you tied to particular software?
No. We do not sell software and receive no fees from vendors. If you already run an AML platform, we work inside it. If you work with spreadsheets and a shared drive, we will tell you honestly when that is adequate and when it is not.
Related
Wondering whether this fits? The one-hour intake costs nothing and always produces something — if only a short list of what needs to happen first. Book a call.