Enigma Consulting can help you with an end-to-end CDD & AML solution.

With increasing pressure from regulators, the CDD and anti-money laundering process have been in the spotlight in recent years. Legislation, regulators and public opinion are forcing financial institutions to make substantial investments in systems as well as attracting additional manpower.

Setting up and optimizing the customer onboarding and anti-money laundering process is an intensive process and takes place in a complex playing field. Many financial institutions lack the time and knowledge to set up an adequate and high-quality CDD and AML Framework.

Do you need support in implementing or optimizing your CDD and AML process? We have developed a roadmap that can help you with your CDD & AML challenges. If you have any questions, please contact one of our consultants, they will be happy to help you.

Jaap Jan de Jong
Jaap Jan de Jong
Executive Consultant



Conducting a Risk Analysis (SIRA) is an important first step to identify all your risks with regard to money laundering, terrorist financing, but also fraud and tax evasion. Enigma has specialist knowledge of all financial products and how they are susceptible to the above risks. Together we map out all risks and specific scenarios and propose measures to limit the risk. It is important to keep your risk analysis up to date.



Financial institutions are obliged to identify and verify their customers on a risk-based basis. This means that one customer must be identified more intensively than another. Client risk profiles determine how the client must be identified and verified. A CDD Risk Matrix determines the ultimate risk with regard to money laundering and terrorist financing and also determines the degree of review and monitoring.


Transaction Profiles

Transaction profiles are essential to determine in advance what the expected transactions are from the customer. It is important here that the transaction profiles are well-founded and accurate. We have extensive income and payment data that can help you map customer expectations as accurately as possible. Because income and payment data is subject to macroeconomic changes, we can help you keep your transaction profiles as up-to-date as possible. An up-to-date transaction profile enables you to detect forms of money laundering, terrorist financing, fraud and tax evasion at the earliest possible stage.


Business rules

Business rules are necessary to detect forms of money laundering, terrorist financing, but also fraud and tax evasion. The business rules must not only be clear and clear, but also have a clear connection with the Risk Analysis and the associated scenario descriptions. The results of business rules and the resulting hits will have to be further investigated and analyzed. We help you describe business rules but also detect and process “true hits” and reduce “false positives”. Where necessary, we ensure affiliation with the FIU; the authority to which you must report Unusual Transactions.


AML software selection process

Systematically detecting and handling AML alerts can be a time-consuming aspect of your day-to-day work. An automated AML system helps you to significantly reduce time pressure. We can help you map both functional and non-functional requirements. Because we have mapped the entire AML market, we can switch quickly with the right parties.


Through many years of experience in the payments and compliance domain, Enigma has developed a unique and above all pragmatic step-by-step plan in which the customer is intensively guided from start to finish. With the aim: to be able to organize and carry out CDD and AML tasks yourself without the help of external parties.

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Our Risk & Compliance Experts

Arjan Bom

Senior Legal Consultant
Arnoud van Sterkenburg

Dorothé Beernink

Managing Partner
Erik van der Leer

Jaap Jan de Jong

Executive Consultant
Kaj van der Peet

Lex van Beurden

Maarten van Denzen

Senior Legal Consultant
Peter Mulders

Executive Consultant
Roland Hols

Roxane van der Laan

Executive Consultant
Thim Donkervoort

Senior Legal Consultant