AML for neobanks · engineering partner
AML compliance for neobanks,
engineered for volume and audit.
TrustChange builds AML compliance for neobanks — the control layer that sits across onboarding, screening, monitoring and reporting. We engineer bespoke KYC flows, sanctions and PEP screening, a rule and typology monitoring engine, aged alert queues and MLRO-ready reporting under your brand — not a SaaS licence with a per-customer fee. Client-owned code, EU-hosted infrastructure, audit evidence in from day one.
- EU-based engineers
- PSD2-aware fields
- AML & sanctions in code
- Travel Rule aware
- GDPR-aware storage
What "neobank" means here
AML compliance for neobanks, without the SaaS strings
Most searches for AML compliance for neobanks surface multi-tenant SaaS with a fixed customer model, a rented case queue and a per-customer fee. We work the other way. TrustChange is a bespoke AML compliance for neobanks engineering partner: your customer classes, your rules, your vendor mix, your evidence, your code. Every rule version and every export stays on your platform — not on someone else's.
Deciding whether to build, wrap or replace an incumbent? Start with CTO advisory. The wider AML practice sits on compliance engineering. Adjacent shapes: AML compliance for fintechs, AML compliance software for banks and AML compliance for payment platforms.
Toolset
Three toolset areas in every neobank AML engagement
AML for neobanks is not one tool. It is onboarding at retail scale, transaction monitoring across rails, and an alert queue with MLRO-ready reporting behind it. We build the three together, on one plan, with one team accountable end to end.
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01
Retail onboarding at scale
KYC flows for individuals, sole traders and businesses — with document, biometric, liveness and beneficial-owner checks — sized for neobank sign-up volume without dropping the fraud line.
- KYC / KYB flows
- Liveness + biometrics
- UBO & business registry
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02
Transaction monitoring
Rule-based monitoring on card, SEPA, Instant, open-banking and internal transfers — with typologies engineered for neobank patterns (velocity, structuring, mule networks, sudden spend shifts).
- Rule + typology engine
- Cross-rail correlation
- Peer-network signals
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03
Alerts, cases & SAR/STR
Aged alert queues, analyst case files, four-eyes gates on manual overrides, MLRO dashboards and reviewer-shaped SAR / STR bundles.
- Aged queues by SLA
- Four-eyes gates
- SAR / STR export
Stack
What sits behind AML compliance for neobanks
Eight layers, one system. Every layer names an owner, a control and a piece of audit evidence — nothing is left implied under the "neobank AML" label.
Delivery patterns and evidence: how we deliver. Wider platform view: banking software development company and fintech infrastructure.
| Layer | What we build |
|---|---|
| Customer model | Typed customer records for individuals, sole traders and businesses with lifecycle state (onboarded, restricted, off-boarded) One canonical shape, versioned in your repository. |
| KYC / KYB integrations | Adapters into ID verification, biometrics, liveness, business-registry and UBO vendors — with cached verdicts and re-verification triggers Vendor mix is configuration; swap a provider without a code change. |
| Screening pipeline | Sanctions, PEP, adverse-media and internal-list screening at onboarding, before regulated actions and on scheduled refresh Every hit stores vendor id, matched entity, list version and reviewer decision. |
| Transaction monitoring | Rule and typology engine across card, SEPA, Instant and open-banking flows, with cross-rail correlation and case grouping Rules are configuration, reviewable and versioned in the admin console. |
| Alert & case workflow | Aged queues, assignment, notes, evidence attachments, resolution codes and re-run on individual cases SLAs and escalation are enforced by the engine, not by inbox habit. |
| Regulatory reporting | SAR / STR bundles, MLRO dashboards, close packs and reviewer-shaped exports for local FIU shapes Regulator-shaped exports out of the same store as ops reports. |
| Controls & access | SSO, role-based access, four-eyes on manual overrides, tamper-evident audit log, retention rules per case class GDPR-aware storage, EU-hosted by default, PII bounded by policy. |
| Runtime & delivery | EU-hosted, CI/CD pipelines, observability, 24/7 on-call cover Your identity provider, your data regions, your access rules. |
Alert path
From sign-up to a defensible SAR bundle
Every customer and every transaction on the neobank goes through the same gates. Speed comes from tuning the pipeline, not from skipping a step or trusting a vendor result forever.
- 01
Onboarding
Sign-up
KYC / KYB runs against your vendor mix; the customer record stores verdict, vendor id, list version and lifecycle state.
- 02
Screening
Sub-second
Sanctions, PEP and adverse-media screening return a verdict; cached results refresh under policy.
- 03
Live activity
Streaming
Card, SEPA, Instant and open-banking events feed the transaction monitor as they happen.
- 04
Alerts
Sub-second to seconds
Rules and typologies raise alerts; cross-rail correlation groups related events into one case.
- 05
Review
SLA-bound
Analyst reads the evidence, adds notes, decides. Four-eyes gate applies above defined thresholds.
- 06
Report
Daily / on-event
Close packs, MLRO dashboards and SAR / STR bundles publish from the same store, ready for the FIU shape you file.
Delivery
How we deliver AML compliance for neobanks
Five steps, in this order. Regulated AML work runs inside the product backlog — no separate compliance phase bolted on before launch, no big-bang release of an untested monitoring engine.
- 01
Scoping
Weeks 1–2
We map customer classes, current vendors, MLRO expectations, product mix, licence context and local reporting shapes. Output: a scope, a control map and a costed plan.
- 02
Architecture
Weeks 3–4
Customer model, screening pipeline, monitoring engine, alert workflow and export schemas written down first. Auditor requirements shape the design.
- 03
Build
Two-week sprints
Onboarding, screening, monitoring, workflow and MLRO reporting ship in slices. Each merge runs tests, static checks and a dependency scan.
- 04
Hardening
Before cut-over
Replay against historical customers and transactions, load work, failure drills and a third-party review window. Cut-over is rehearsed with your ops and MLRO team, not assumed.
- 05
Launch and run
Cut-over + ongoing
Named engineers on 24/7 cover. Runbooks, dashboards and the audit bundle are handed to your team on day one, with a documented on-call rota.
Engagement
Four ways to buy your neobank AML build
Same engineers, same standard. Only the commercial shape changes.
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Fixed-scope build
A defined AML control layer at a fixed price and date. Best when customer classes and vendors are settled.
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Dedicated team
A standing squad with a lead. Best for long roadmaps and new typologies each quarter.
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Staff augmentation
Senior engineers inside your team. Best when you already own the plan and need control-layer depth.
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CTO advisory
Architecture and buy-vs-build review before you commit. Best at the design stage.
Questions
FAQ: AML compliance for neobanks
Six answers up front on scope, off-the-shelf trade-offs, typologies & rails, MLRO reporting, PSD2/MiCA/AML/GDPR and support. Bring the rest to the call.
What does AML compliance for neobanks from TrustChange actually cover?
We engineer a bespoke, client-owned AML control layer for the neobank shape: KYC and KYB onboarding sized for sign-up volume, sanctions and PEP screening running before and after live activity, transaction monitoring across card, SEPA, Instant and open-banking rails, alerts and case workflow, MLRO dashboards, and SAR / STR bundles ready for the local FIU shape you file. It ships as source code in your repositories, with the IP assigned to you.
How is your build different from off-the-shelf AML software for neobanks?
Off-the-shelf AML tools bundle a generic customer model, a fixed vendor mix and a licence fee. TrustChange shapes the customer classes, screening cadence, monitoring rules and reporting against your actual neobank product mix (accounts, cards, savings, credit, SME), your vendor mix and your local reporting needs. A bespoke build takes longer up front, but you keep every rule, every adapter and every decision — and you avoid the roadmap lock-in that comes with a rented tool.
Which typologies and rails does the monitoring engine cover for a neobank?
Rails: card acquiring and issuing, SEPA and SEPA Instant, open-banking pay-ins, internal transfers between customers, and crypto legs where the neobank offers digital-asset accounts. Typologies you configure include velocity spikes, structuring, mule-network patterns, sudden geographic or merchant-category shifts, high-risk MCC exposure, first-party fraud indicators and cross-account correlations. The engine ships the plumbing; your policy defines what fires.
How does the platform support MLRO reporting and SAR / STR filings?
MLRO dashboards summarise open alerts, aged cases, SLA misses and case-class trends. SAR / STR bundles export in shapes local FIUs expect (per your compliance team's mapping), with the case file, evidence attachments and rule/version metadata attached. TrustChange is an engineering partner, not an MLRO — your team owns the filing decision, we ship the tooling and the audit-log evidence behind it.
How are PSD2, MiCA, AML/Travel Rule and GDPR engineered into the platform?
TrustChange is an engineering partner, not a law firm — your compliance team and MLRO set the policy, we ship the controls and the evidence. That means PSD2-aware fields on payment flows and open-banking consent, MiCA-ready records where a neobank offers digital-asset accounts, sanctions and monitoring rules that run inside the flow, Travel Rule messaging on crypto transfers, and GDPR-aware storage with data mapping and retention rules per case class. Nothing about licences, opinions or supervisor approvals is claimed on your behalf.
Do you also run the AML control layer after launch, or hand it over?
Both are on the table. Most clients start with named TrustChange engineers on 24/7 cover during the first months while their own team ramps up, then take the platform in-house with runbooks, dashboards and an on-call handover we author together. Some keep us on as a dedicated development team or on staff augmentation for new-vendor adapters, rule roadmap and integration with adjacent systems.
Book a discovery call for AML compliance for neobanks
Bring the customer classes, the product mix, the current vendors, the reporting shapes and where the pain sits — false positives, aged queues, missed SLAs or a stuck MLRO export. We come back with a control map, an architecture view and a costed plan. No demo theatre.