Raising the Bar


We tailor our services to our clients' needs but our involvement is often on one of these levels:


LMRR has extensive experience in anti-money laundering and countering terrorist financing.  We can assist with:

  • Implementing and assessing policies procedures and controls
  • Reviewing business risk assessments 
  • Carrying out reviews of existing and proposed clients
  • Adapting to the regular changes in the global AML/CFT framework 
  • Managing bribery and corruption and sanctions risks.

Suitably experienced LMRR staff will act as MLRO/MLCO (or Nominated Officer) where we have a good understanding and experience of the business.

Enhanced CDD

LMRR has a relationship with C6 Intelligence (part of the Mergemarket Group) where KYC6 searches can be carried out on individuals and corporates for a nominal fee.

At our usual consulting rates our team can also help you to interpret EDD reports and suggest any further action required.

Compliance monitoring

There is a regulatory expectation, and in many cases a requirement for firms to test whether they are meeting their regulatory requirements.  Such “compliance monitoring programmes” can take a variety of forms.

LMRR is expert in:

  • Reviewing compliance monitoring programmes 
  • Helping with establishing CMPs and writing tests or assessing the effectiveness of existing CMPs
  • Running the CMP for clients as a compliance support function.

Data protection

LMRR has professional expertise in this area and provides data protection support services and advice to data protection officers and directors of all businesses.

Our data protection services include:

  • Assessment sheets to help businesses independently map the personal data they process

  • Assistance with drafting or assessment of DP policies, procedures and controls against the requirements of relevant data protection legislation

  • Undertaking a mapping and assessment exercise

  • Ongoing data protection support including:

    • Advice on data protection impact assessments

    • Assisting with subject access requests

    • Reviewing compliance with the Guernsey DP Law and GDPR.

Compliance support

LMRR provides:

  • Compliance support;

  • A Compliance Officer, and/or

  • MLRO/MLCO/Nominated Officer

This can be for short- or longer-term, including on a regular time-tabled basis. 

Where this can be useful:

  • Smaller firms whose activities do not require or merit a full-time compliance resource

  • Support and guidance/training for personal fiduciary licensees and non-executive directors

  • Larger businesses where the internal team needs assistance or development

  • Where workloads fluctuate with business flows, scheduled events during the year, business or corporate activity and regulatory focus

  • Short or long-term contract hours to boost a compliance function without the implications of expanding your permanent team

  • Assistance with complaints-handling, acting as an independent voice

  • Providing a continuing relationship under which we are available for prompt input or advice

  • To cover internal compliance absences, difficult situations or unusual issues

  • Provision of experts “on call” for ad hoc advice with prompt responses.

Regulatory visits/liaison

LMRR has senior staff with unrivalled experience both as regulators and in liaising with regulators. This means we can provide specialist services including:

  • Advice on specific regulatory issues, returns, submissions or applications

  • Wide experience with licence applications from initial contact with regulators to completion of applications and addressing regulators’ enquiries

  • Pre-regulatory inspection to help with preparation for the visit and to flag likely issues in advance

  • Post-regulatory inspection and assistance with managing the resolution of findings

  • Risk Mitigation Programme support: we have considerable experience in helping with specific actions and in helping to manage the RMP as a whole

  • Helping to put issues in proportion and focus efforts on resolving any points of substance

  • Assistance when regulatory enforcement action is being considered

  • Substantial experience in independent reviews both as regulators and on behalf of firms. We understand the importance of negotiating the right scope as well as delivering a robust and constructive report

  • Resolving post-inspection issues in a pragmatic and practical way, either in direct discussions with regulators or helping firms to correspond effectively with them.

Policies and procedures

  • Experienced in advising on and drafting clear policies and procedures which staff can understand and follow

  • Not “off-the shelf” so we can suggest revisions to the client’s existing documents

  • Help firms meet their obligations without over-engineering their policies and procedures.


LMRR offers an experienced and independent perspective view on a firm’s governance or its compliance function. For example:

  • Formal reviews of the compliance function for firms without an internal audit function

  • Constructive input in areas such as risk assessment or governance

  • Reviews of governance under the Finance Sector Code of Corporate Governance

  • Conduct risk reviews

  • Reviewing the effectiveness of their compliance monitoring programme.

We are experienced in putting together good quality teams of reviewers to carry out file or risk reviews which may be required either as a remediation requirement set by the regulator or post acquisition or merger.

We also carry out projects such as sample file reviews for internal assurance purposes, and retrospective CDD reviews.

Public sector

LMRR has a combined experience of some 45 years as regulators and we have all worked in the public sector. 

  • We understand that regulators’ responsibilities often require them to respond to events urgently, and can offer additional resources for such situations

  • Equally we can assist regulators with projects such as drafting rules, onsite inspection questionnaires, policies and procedures – Chris, Stephen and Maxime all have experience in drafting important items of secondary legislation and codes.


Our experience is that time spent examining the target business’s risk and compliance history avoids unexpected problems and expense later.  We provide expert and confidential assistance in this area including due diligence on:

  • Regulatory standing

  • Risk and compliance framework and functions.

Please contact us for more information on how LMRR can help you with your compliance needs.