KYC/ODD Team Outsourcing for Fintech & EMI

EU-based KYC & ODD
analysts, operational
in two weeks.

We provide outsourced KYC/ODD analyst teams to fintech companies, EMIs, and payment institutions across the EU — fully remote, ready in two weeks, at 40–50% lower cost than building in-house, with no recruitment fees and a 30-day scale-down clause.

ACAMS-certified team leads, 5y+ experience
Teams in PL · LT · LV · EE
Operational in 2 weeks
40–50% cost vs. in-house
CET/EET time zones
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2wk
Onboarding from engagement to live team
EU-based
All analysts operating in CET/EET time zones
4+
Regulatory frameworks covered per engagement
0
Placement fees — monthly fixed-rate model
Who We Work With

Built for regulated
financial companies in the EU

💳

Electronic Money Institutions

EMIs carry full AML obligations under AMLD6 and face intense supervisory scrutiny. We provide embedded KYC/ODD teams and MLRO support that meets the standard your NCA actually expects.

AMLD6 · EBA Guidelines · NCA supervision
🏦

Payment Institutions & Neobanks

High transaction volumes require scalable, accurate KYC and ongoing monitoring. Our teams handle CDD, EDD, PEP and sanctions screening at the volume and quality your licence demands.

PSD2 · AMLD · PCI-DSS adjacent
💰

Fintech Lenders & BNPL

Consumer credit AML obligations are growing. We help lending fintechs build KYC infrastructure that satisfies both AML requirements and credit risk appetite — without duplicating work.

CCA · AML · Responsible lending

Crypto CASPs under MiCA

MiCA requires CASPs to demonstrate full AML substance — not just policy documents. We provide MLRO outsourcing, KYC team support, and the on-chain analytics capability that MiCA requires.

MiCA · AMLD · TFR · FATF
🌍

Non-EU Companies Entering Europe

US, UK, and APAC companies launching EU-licensed entities need to build AML infrastructure quickly. We handle the team, the MLRO role, and the programme — from licence application through to live operation.

EU market entry · Substance · AMLD
⚙️

RegTech & B2B Compliance Platforms

If you build compliance tools for regulated clients, we can provide the AML expertise your product needs — whether that's advisory, audit validation, or analyst teams embedded alongside your technology.

Product compliance · AML validation
What We Do

Four services.
One trusted team.

Every engagement starts with understanding your regulatory obligations, your current AML infrastructure, and where the gaps are. We scope before we propose — no generic retainers.

S1 — Outsourcing

KYC / ODD Team Outsourcing

EU-based KYC analysts and ODD investigators provided remotely, fully aligned to your AML policies, risk appetite, and regulatory framework. Scalable from a single analyst to a full team. Onboarding from two weeks.

  • Customer Due Diligence (CDD) — individual and corporate
  • Enhanced Due Diligence (EDD) for high-risk customers
  • PEP, sanctions and adverse media screening
  • Ongoing monitoring and periodic review
  • Case management and SAR preparation support
  • Quality assurance and team lead supervision
Pricing: Monthly fixed rate per analyst · No placement fees · 30-day ramp-down · Scales with your volume
S2 — Outsourcing

MLRO & Deputy MLRO Outsourcing

A senior, qualified MLRO or Deputy MLRO provided on a fractional or full-time basis — with real regulatory accountability, independent reporting lines, and the mandate to actually run your AML programme.

  • Statutory MLRO role with full regulatory accountability
  • AML programme ownership and oversight
  • SAR submission and FIU liaison
  • Regulatory examination preparation and representation
  • Board and senior management reporting
  • Staff AML training and awareness programme
Pricing: Monthly retainer · Fractional or full-time · Independent reporting line to board
S3 — Advisory

AML Programme Design & Advisory

Gap assessment, programme design, policy and procedure documentation, and ongoing advisory for fintechs building or overhauling their AML framework — including MiCA-specific AML substance requirements for crypto CASPs.

  • AML gap assessment against AMLD6 and EBA guidelines
  • Business-wide risk assessment (BWRA) design
  • AML policy and procedure documentation suite
  • Transaction monitoring rules and typology design
  • MiCA AML substance — MLRO, policies, travel rule
  • AML policy and procedure writing
Pricing: Fixed fee per project · Typical range €5,000–€18,000 depending on scope
S4 — Assurance

AML Audit & Independent Review

Independent AML effectiveness audit, pre-examination health check, and thematic reviews — producing structured, reusable evidence aligned to ISO 19011 methodology and mapped to your regulatory obligations.

  • Independent AML effectiveness audit
  • Pre-NCA examination health check and readiness review
  • Thematic review — PEP, sanctions, high-risk customers
  • Transaction monitoring effectiveness assessment
  • Remediation planning and implementation support
  • Board-ready audit report with findings and recommendations
Pricing: Fixed fee per engagement · Typical range €6,000–€20,000 depending on scope
Why Outsource

Why fintech companies outsource
AML to us

Speed to compliance

Building an in-house AML team takes 3–6 months. Our teams are operational in two weeks — against the same regulatory clock your NCA is watching.

💶

Predictable cost

Monthly fixed rates with no recruitment fees, no employer NI, no redundancy risk. Budget certainty at the exact moment your compliance spend is under scrutiny.

🎯

Regulatory-grade expertise

Your analysts and MLRO have done this before — in regulated environments, under real supervisory pressure. Not compliance generalists learning on the job at your expense.

📈

Scales with your growth

Add analysts as your customer volume grows. Scale down in 30 days if you need to. No headcount commitments, no organisational restructuring, no awkward conversations.

How It Works

From first call to
live team in two weeks.

We scope before we propose. Every engagement starts with understanding your regulatory framework, current infrastructure, and gap — so the team we provide is configured to your actual situation, not a generic template.

1
Week 1

Scoping Call

We review your AML framework, understand your regulatory obligations, and assess your current gap. You receive a written proposal with team configuration, timelines, and fixed monthly rate.

Output: Written proposal + pricing
2
Week 1–2

Onboarding

We review your AML policies, access your systems with least-privilege credentials, and brief the team on your risk appetite and customer typologies. NDA and data processing agreements signed.

Output: DPA + onboarding checklist
3
Week 2+

Live Delivery

Your team begins working your case queue — CDD, EDD, PEP/sanctions screening, ongoing monitoring. Weekly quality reporting. Escalations handled same-day.

Output: Weekly QA metrics + case reports
4
Ongoing

Review & Scale

Monthly performance review against your AML KPIs. Team scales up or down with 30 days' notice. Regulatory changes flagged and programme updated as needed.

Output: Monthly performance report
Build vs Buy

Outsource vs.
building in-house

For most fintech companies at Series A to C, outsourcing is the faster, cheaper, and lower-risk path to AML compliance. The in-house model makes sense when you have predictable, high-volume throughput and the management bandwidth to run a compliance function.

Comparison — outsourced team vs. in-house hire
In-House Hire
Scanlex Outsourcing
Time to operational
3–6 months
2 weeks
Recruitment cost
€5,000–20,000
Zero
Regulatory expertise
Varies by candidate
Guaranteed baseline
Scale down flexibility
3–6 month notice
30 days
Management overhead
High — HR, training, retention
Low — we manage the team
MLRO independence
Harder to establish
Built-in by design
What our clients say triggers the call
Licence application or renewal

The NCA wants to see a functioning AML team and a qualified MLRO before granting or renewing a licence. We provide both — fast enough to meet the application timeline.

Regulatory examination scheduled

An upcoming NCA visit or audit. We provide an independent gap assessment and, where needed, embed analysts to clear the backlog before examiners arrive.

Existing team underperforming

High false-positive rates, case backlogs, or SAR quality issues. We audit your current operation and either supplement or replace the function.

Rapid customer growth

Onboarding volumes outpacing your KYC capacity. We scale the team in 30 days — no recruitment cycle, no quality dip.

MiCA & Crypto AML

AML substance for
CASPs under MiCA

MiCA requires crypto asset service providers to demonstrate genuine AML substance — not just policies on paper. Regulators expect a qualified MLRO, a functioning KYC team, and documented processes that actually run. The template compliance packages being sold in the market will not pass an NCA examination.

We provide operational AML substance for CASPs — including MLRO outsourcing, KYC analyst teams, AML programme documentation, Travel Rule implementation, and ongoing monitoring. We work with CASPs applying for their MiCA CASP licence and those already licensed needing to upgrade their compliance infrastructure.

MLRO outsourcing with full statutory accountability under MiCA
KYC/ODD team for crypto customer onboarding and EDD
Travel Rule (TFR) implementation and VASP screening
AML programme documentation — policies, BWRA, procedures
On-chain transaction monitoring and analytics support
Pre-NCA examination readiness review
Discuss your MiCA AML needs
MiCA AML obligations at a glance
📋
Qualified MLRO required

MiCA Article 38 requires CASPs to appoint a qualified AML officer with genuine responsibility and independence — not a nominal appointment.

🔍
Customer due diligence

Full CDD/EDD obligations apply to all CASP customers. Ongoing monitoring required. High-risk jurisdictions and PEPs require enhanced procedures.

✈️
Travel Rule (TFR)

The Transfer of Funds Regulation requires CASPs to collect and transmit originator and beneficiary information on crypto-asset transfers — with VASP screening obligations.

⛓️
On-chain monitoring

Transaction monitoring must cover both fiat and on-chain activity. Regulators increasingly expect blockchain analytics capability as a standard.

📊
Business-wide risk assessment

A documented BWRA covering customer risk, product risk, geographic risk, and channel risk — reviewed annually and updated for regulatory changes.

Client Testimony

What compliance teams say
about our KYC/ODD teams

"

We were under pressure from the MFSA ahead of our annual AML review. Our KYC backlog had grown to a point where we couldn't clear it with our existing team. Scanlex deployed four analysts within ten days. They integrated into our systems, followed our procedures exactly, and cleared the backlog two weeks before the review date. The MFSA found no material issues with our KYC function. That was a direct result of the work Scanlex put in under real time pressure.

Head of Compliance — EMI, Malta
"

We brought Scanlex in when our customer onboarding volumes doubled in three months and our internal KYC team simply could not keep pace. Two analysts were operational within two weeks. The handover was clean, the quality was consistent from day one, and we didn't have to manage them — they managed themselves and reported to us weekly. Exactly what we needed.

MLRO — Payment Institution, Denmark
"

We compared three outsourcing providers before choosing Scanlex. What decided it was the quality of their onboarding process — they reviewed our AML policies, asked the right questions about our customer base, and came in already calibrated to our risk appetite. Six months in, their ODD output quality matches what our best in-house analyst produces.

Chief Compliance Officer — EMI, Lithuania
"

As a Cyprus-licensed PI we needed a KYC/ODD team that understood CySEC expectations and AMLD6 requirements simultaneously. Scanlex delivered both. They handle our ongoing EDD reviews and high-risk customer monitoring. The cost compared to expanding our internal team is significantly lower — and the regulatory quality is higher than what we had before.

Head of Operations — Payment Institution, Cyprus
Case Studies

What outsourcing actually
delivers — in numbers

Three client engagements — different situations, same result: faster compliance, lower cost, and regulatory pressure resolved.

Case Study 01 — EMI
Regulatory Crisis

Top-5 EU EMI: Critical KYC backlog cleared before Bank of Lithuania audit

A top-5 Lithuanian-licensed EMI had accumulated a critical card transaction monitoring backlog with an NCA audit imminent. Previous fines had reached €500,000–600,000. Scanlex deployed a dedicated ACAMS-supervised AML team within two weeks. KPI targets exceeded by 30% weekly. Operational control restored ahead of the audit date.

Reduction in regulatory fines
30%
Weekly throughput above KPI
Transaction monitoring · Backlog clearance · ACAMS oversight · Audit pass
Case Study 02 — Payment Institution
Rapid Scaling

EU Payment Institution: ODD & EDD backlog resolved — team scaled from 2 to 12 in 30 days

A high-growth EU payment institution had accumulated an extensive ODD/EDD backlog across a high-risk customer base. Scanlex scaled from an initial 2-analyst team to 12 within 30 days, building custom SOPs and training methodology for long-term operational quality. All targets were met one week ahead of the agreed deadline.

2→12
Team scaled in 30 days
−1wk
Completed ahead of deadline
ODD/EDD · Rapid scaling · Custom SOP · High-risk customer base
Case Study 03 — EMI
Long-Term Outsourcing

EU EMI: Full KYC/ODD function outsourced — €60,000+ annual cost saving vs. in-house team

A licensed EU EMI outsourced its entire first-line KYC/ODD function — onboarding, ongoing due diligence, transaction monitoring, QA, and internal audit — to Scanlex as a long-term managed service. The engagement replaced an equivalent in-house team at 40–50% lower total cost, with no recruitment overhead and guaranteed regulatory currency as AMLD requirements evolved.

€60k+
Annual labour cost saving
45%
Lower cost vs. in-house
KYC/ODD · Ongoing monitoring · QA · Long-term managed service

References available upon request for qualified prospects. All case data verified by engagement records.

Discuss Your Situation
FAQ

Questions from
compliance &
legal teams

Can't find your answer? Contact us directly — we respond within one business day.

How quickly can you mobilise a KYC team?+
Fractional or small team coverage (1–3 analysts) can typically be mobilised within two weeks of engagement confirmation — including onboarding to your systems, review of your AML policies, and briefing on your customer typologies. Larger teams (4+) take 3–4 weeks. We have never missed a mobilisation deadline agreed at engagement start.
Where are your analysts based?+
All our analysts are EU-based, operating in CET/EET time zones. This matters for two reasons: regulatory — EU data residency requirements are met by default; and operational — your team is reachable during your business hours without coordination overhead. We do not use offshore analysts.
What does MLRO outsourcing actually mean in practice?+
Our MLRO takes on the full statutory role with genuine regulatory accountability — not a nominal appointment. This means: owning the AML programme, reviewing and approving SARs, reporting to your board and senior management, liaising with your NCA, attending regulatory examinations, and being genuinely reachable when compliance decisions need to be made. The MLRO reports independently to your board, not to the CEO or commercial function — which is what regulators require.
How do you handle data security and GDPR when accessing our systems?+
All access is on a least-privilege basis — analysts access only the systems and data necessary for their specific function. We sign a Data Processing Agreement (DPA) before any access is granted, data remains in the EU throughout, and all activity is logged with audit trails available to you at any time. Our DPA is aligned to GDPR Article 28 requirements.
Can you help us prepare for an NCA examination?+
Yes — pre-examination readiness is one of our most frequently requested services. We conduct an independent gap assessment against the specific obligations your NCA will examine, identify and remediate critical findings before the examination date, clear any case backlogs, and brief your team on examination conduct. We have supported companies through NCA examinations across Estonia, Lithuania, Latvia, Poland, and the Netherlands.
What is your pricing model?+
KYC/ODD analyst teams are priced on a monthly fixed-rate basis per analyst — no placement fees, no recruitment costs, no employer social costs on your side. The rate varies by seniority (analyst, senior analyst, QA lead). MLRO outsourcing is a monthly retainer. Advisory and audit engagements are fixed-fee projects, scoped and agreed before work begins. We provide a written proposal with all costs before any engagement starts.
Do you work with companies that are not yet licensed?+
Yes. We frequently work with companies during the licensing process — building the AML infrastructure that the NCA needs to see before granting a licence. This includes MLRO appointment, AML programme documentation, and KYC process design. We can also advise on jurisdiction selection for EMI or CASP licensing if that is still under consideration.
How are you different from a staffing agency?+
A staffing agency places a candidate and their involvement ends there. We provide a managed compliance function — we supervise the team, maintain quality standards, manage escalations, ensure regulatory currency, and take accountability for outcomes. If an analyst leaves, we replace them without disruption to your operation. The regulatory expertise sits with us, not just with the individual placed.
Get in Touch

Tell us your situation.
We'll tell you exactly
what you need.

Send us a brief message and a senior advisor will respond within one business day — with an honest assessment of which service fits your situation and what it will cost. No sales team. No obligation.

Team operational within 2 weeks of engagement
EU-based analysts — CET/EET time zones
Fixed monthly rates — no placement fees
MLRO with genuine statutory accountability
Response within one business day guaranteed
GDPR-compliant — data stays in the EU

We respond within one business day · Data handled under GDPR · Never shared with third parties

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