Claritas
Madrid Cuatro Torres financial district at dusk.
Claritas Risk Advisory

We find the weaknesses before the regulator does.

Independent AML, remediation and regulatory readiness advice for smaller regulated firms across Europe.

Every engagement is personally led by Everett Morgan, drawing on more than twenty years of AML and financial crime experience at Deutsche Bank, Morgan Stanley, BNP Paribas and other international financial institutions. A small network of trusted specialists is available where broader capability is genuinely required.

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Why firms engage Claritas

You may recognise the moment.

Most conversations begin when something has shifted, or is about to. If any of these sound familiar, an initial conversation is usually the right next step.

  • 01Preparing for a regulatory inspection
  • 02Responding to Internal Audit findings
  • 03Strengthening AML governance
  • 04Beginning or steadying a remediation programme
  • 05Preparing for AMLR
  • 06Seeking independent Board assurance

Not every situation calls for external support. If Claritas isn't the right fit, we will say so.

Why Claritas

Three reasons clients choose Claritas Risk.

  • 01

    Personally led

    Every engagement is delivered by an experienced adviser. No junior teams, no rotating faces.

  • 02

    Independent judgement

    Recommendations shaped by evidence and experience, not by a template or a follow-on sale.

  • 03

    Practical and proportionate

    Advice sized to your firm's risk profile. Where existing arrangements are appropriate, we say so.

How we work

One methodology. Four steps.

From first conversation to regulatory confidence.

  1. 1

    Understand

    Your business, your people, your systems and what you're actually grappling with.

  2. 2

    Assess

    Governance and controls tested against what supervisors expect in practice.

  3. 3

    Recommend

    Recommendations prioritised by risk, business impact and what can realistically land.

  4. 4

    Support

    Where useful, we stay alongside the team through implementation and regulatory preparation.

Selected engagement

One recent piece of work.

Strengthening AML Governance Through Independent Oversight

Six successive annual MLRO reports drafted, challenged and signed off, each grounded in evidence the Board could test.

Challenge

A large international financial institution engaged Claritas, over six successive years, to support preparation of the annual MLRO report. Material had to be drawn together from transaction monitoring, investigations, sanctions, customer due diligence, remediation, training and senior management engagement, and turned into an honest read on how the financial crime controls were operating in practice, not how they were described in the policy.

Approach

Met monthly with the MLRO. Read the governance packs, transaction monitoring MI, investigations updates, sanctions reporting, CDD quality data, remediation progress and financial crime training metrics before each meeting.

Outcome

Six MLRO reports delivered on time across six successive years.

View all case studies
Practical resources

Guides for Boards, MLROs and Compliance teams.

Short practical guides to strengthen governance, prepare for regulatory scrutiny and manage AML remediation.

Claritas Practical Guide · 001

10 Questions Every Board Should Ask Before the Regulator Does

Ten Board-level governance questions, with a structured self-assessment and score guide.

10 min read · PDF

Get the guideRead more
Claritas Practical Guide · 002

Is Your AML Remediation Programme Set Up to Succeed?

Nine sections covering governance, quality assurance, MI, Board reporting and root cause analysis.

12 min read · PDF

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Claritas Practical Guide · 003

Preparing for an AML Inspection

Eight focus areas from governance and CDD through to evidence preparation, with a readiness score.

12 min read · PDF

Get the guideRead more
View all guides
Latest thinking

Perspectives from the work.

Practitioner notes on governance, remediation and regulatory practice.

Madrid Cuatro Torres financial district at sunset
Regulation

What Spain's recent AML enforcement activity says about regulatory expectations.

12 min read

A modern European executive boardroom at dusk
Governance

Five questions every Board should ask about its financial crime controls.

6 min read

European institutional architecture in soft light
Practice

Why independent challenge matters more than another policy review.

6 min read

Explore all Perspectives
Client feedback

What clients say about working with Claritas.

A short selection of feedback from senior stakeholders at regulated financial institutions. Roles are shown; organisations and locations remain confidential.

  • “Everett provided independent governance oversight for a complex AML remediation programme covering customers across Europe and South and Central America. He chaired governance meetings, reviewed programme management information, challenged delivery assumptions and acted as the point of reference for complex customer cases and governance decisions. His structured approach and clear communication kept the programme focused, allowing it to be completed ahead of schedule and within budget.”
    Chief Risk Officer
    Regulated Financial Institution, London
  • “Everett joined the programme after the FCA identified significant weaknesses in our AML control framework. His role was not to argue with the findings, but to help us respond properly. He coordinated governance, reviewed evidence, tracked remediation activities and worked directly with the independent reviewer appointed by the FCA to oversee the programme. His calm, structured approach gave senior management confidence that commitments made to the regulator were being delivered and that progress could be clearly evidenced.”
    Head of Financial Crime
    Global Investment Bank, London
  • “We engaged Everett to carry out an independent review of our financial crime governance before expanding into additional jurisdictions. He spent time understanding how decisions were actually being made, reviewed customer due diligence standards, management information and governance reporting, and identified where responsibilities needed to be clearer. The recommendations were practical, balanced and straightforward to implement, giving the Board a clearer understanding of where governance was working well, where improvements were needed, and how those improvements could be delivered.”
    MLRO
    Payment Institution, Madrid
Begin a conversation

Better decisions start with an independent view.

You'll be speaking to the person doing the work.

Book a Confidential Strategy Call

If Claritas isn't the right fit, we'll tell you so.