December 8, 2025 · 1 min read · Harlyz Advisory
Why AML readiness breaks at scale
High-growth brokers often inherit monitoring rules and onboarding controls that were designed for lower volume. The result is a fragile system that either blocks too many clients or misses genuine risks. Regulators expect evidence that controls evolve with volume, products, and jurisdictions.
A practical readiness framework
- Re-map your risk model against the product and jurisdiction mix.
- Define risk ownership across operations, compliance, and product.
- Automate evidence capture for onboarding, monitoring, and investigations.
What good looks like
A credible AML program combines consistent controls, traceable decisioning, and a clear escalation path. Teams should be able to show how alerts are investigated, how SAR decisions are made, and how training is kept current.
Next steps
If your monitoring alerts are scaling faster than your team, start with the risk model and work forward. Small refinements at the inputs level often reduce false positives by double digits.