Pillar 03 · AML / CFT Compliance
AML / CFT Compliance in Uzbekistan
AML is an area where what's written and what's practiced aren't the same thing — and the difference only shows with real experience. We work from how compliance is actually practiced in Uzbekistan, and we build programs that work in reality: across your product, your structure, and your operations.
The basics, plainly
What AML/CFT
means in practice.
Three ideas separate a policy binder from a program that survives licensing, bank onboarding, and inspection.
DefinitionAML/CFT compliance
AML/CFT compliance is the set of controls a financial institution or fintech must run to prevent money laundering and terrorism financing — customer due diligence, transaction monitoring, sanctions and PEP screening, recordkeeping, and reporting to the financial-intelligence unit. In Uzbekistan these duties attach from day one of a financial license, not after launch.
DefinitionThe financial-intelligence unit (FIU)
The financial-intelligence unit (FIU) is the body that receives suspicious-transaction and threshold reports. In Uzbekistan it is the Department for Combating Economic Crimes under the General Prosecutor's Office, and the base law is ЗРУ-660-II. A licensed institution must appoint a compliance officer, adopt internal rules, and report against the law's thresholds.
DistinctionA program, not a binder
Real AML compliance is five things working as one — agreements, policies, structures, people, and products. A set of policies with no compliance officer, no screening that runs, and no monitoring built into the product is a binder, not a program. The parts most firms skip are usually the ones an inspection checks first.
Why us, specifically
Built for how it's
actually enforced.
We understand how AML and sanctions work on the ground — so before you take on a local partner, open with a bank, or onboard a client, we can clear them against real practice.
Operational, not theoretical.
If you're building a product, we tell you what will actually matter in practice — and shape it so compliance is built in from the start, not bolted on later. The difference shows when the regulator looks past the policy document to whether the program runs.
A program, not a binder.
Real compliance is agreements, policies, structures, people, and products working as one. We build all five — the parts most firms skip are usually the ones that matter.
Grounded in real practice.
We understand how AML and sanctions work on the ground — so before you take on a local partner, open with a bank, or onboard a client, we clear them against how things actually get enforced.
AML in Uzbekistan runs on one base law — ЗРУ-660-II — and one financial-intelligence unit, the Department for Combating Economic Crimes under the General Prosecutor's Office, which receives the reports every licensed institution must file. The sector regulator (the Central Bank or NAPP, depending on your activity) supervises the program on top of that. Knowing what each one weighs is the difference between a program that passes and one that's returned — and it's why we tie AML work to your licensing path→ from day one.
A working program is more than its policies. It's a compliance officer who can actually operate, internal rules that match the product, customer due diligence that runs at onboarding, sanctions and PEP screening against the right lists, and transaction monitoring built into the flow. We build all of it to fit the product→, not a generic template — because a template is the first thing an inspection sees through. When you're live, the same program feeds your ongoing compliance function→.
The work doesn't stop at your own perimeter. Before you take on a local partner, open with a bank, or onboard a major client, the risk you inherit is theirs. We pre-clear counterparties, banks, and partners against how enforcement actually works here — so the exposure surfaces before you commit, not in an audit afterward. That clearance runs alongside market-entry and deal work→ and your licensing file→, so one team owns the sequence.
From the policy
to the product flow.
Questions, answered
Concrete, not "it depends."
Requirements, regulators, KYC, sanctions, and pre-clearance — answered directly.
No memo. A map.
Send us the operation, product, or counterparty — we'll tell you how it really works in practice before you commit.
You leave knowing what the program needs, what the regulator will test, and what to fix first.
The proof
30+ products
built legal + AML.
30+ products built legal and AML · 10+ legal & AML due-diligence engagements.
Further reading
Read before you build.
The plain explainer behind this work. All insights →