AML Policy Writing & Review
Need to write or update your AML policy?
Policies and procedures aligned with your business model, risks and jurisdictions: ownership, due diligence, monitoring and escalation.
Explore AML policy services ↗AML POLICY WRITING · KYC · FRAUD AUTOMATION
AML policies.
Controls that work.
Custom AML policy writing and review, KYC procedures and fraud controls for fintechs, crypto exchanges, casinos, iGaming and digital platforms. Supporting operations in the U.S., Brazil and international markets.
BASED IN BRAZIL. WORKING GLOBALLY.
CD / 01
IGAMINGCRYPTO EXCHANGESFINTECH & PAYMENTSGLOBAL TECHNOLOGY
WHAT DOES YOUR OPERATION NEED?
Build the policy.
Make the controls work.
KYC & Screening Procedures
Your team needs a clearer KYC workflow?
Customer journeys, backoffice design, statuses, API requirements and operating manuals. Documented procedures for PEP, sanctions and adverse media.
Discuss KYC and screening ↗Fraud Alerts & Automation
Too many alerts and manual checks, too little useful evidence?
Data-calibrated alerts and automation with zero execution cost within free-tier limits. Intelligent Claude API integrations where AI adds value, with usage controls.
Discuss alerts and automation ↗Experience at scale. Results in operations.
12
years of experience
300+
professionals led across global operations
10
fraud signals implemented with data-driven calibration
≈24k
profiles analyzed to build a device investigation index
Results from previous projects and specific scopes; not a promise of future performance.
01 / THE CONSULTANT
Global technology.
Experience that delivers.
12
12 years of experience in operations, technology and financial services, specializing in U.S. compliance and fraud prevention, with leadership across LATAM, APAC and Europe.
I’m Christiane Delazeri, an operations, compliance and financial crime prevention leader. My experience combines the scale of global technology businesses with hands-on control design, case investigation and automation delivery. I have also designed KYC systems from scratch, connecting the identity verification journey with risk criteria and compliance operations.
In the Atlassian ecosystem, I led support and operations for enterprise products. At Deriv, my experience includes operations management and KYC team leadership. At Ruby Labs, my work brings together AML, fraud prevention and automation. Today, I connect compliance expertise with systems for detection, investigations and risk monitoring.
Atlassian ACA-910 certification · ITSM with Jira Service Management Foundations
02 / INDUSTRIES
Different risks.
Purpose-built approaches.
Controls need to reflect each business’s product, payment methods, user journey and operating model.
01
Casinos & iGaming
KYC, deposit and withdrawal reviews, multiple accounts, promotional abuse and fraud investigations.
Discuss my project ↗02Exchanges & crypto
Onboarding, AML, crypto and fiat transaction reviews, investigations and escalation.
Discuss my project ↗03Fintech & payments
Payment fraud, chargebacks, identity, cross-provider integrations and operational automation.
Discuss my project ↗03 / HOW I CAN HELP
From a complex problem
to the next action.
Each engagement starts with your challenge. Scope, deliverables and a proposal are defined after discussing your operations, priorities and available resources.
Fraud automation.
Zero-cost options.
Business rules, SQL and API integrations for monitoring, data enrichment and alerts. Zero execution cost where volume and architecture fit entirely within free infrastructure tiers, without token consumption.
I also develop intelligent automation through the Claude API for text analysis, evidence organization and investigation support, with human review and usage controls. These projects incur API usage charges. Zero cost for eligible solutions refers to execution, not consulting fees or maintenance.
Discuss an automation project ↗01AML Policy Writing & Review
Need to write or update your AML policy?
Policies and procedures aligned with your business model, risks and jurisdictions: ownership, due diligence, monitoring and escalation.
POTENTIAL DELIVERABLE · SCOPE TO AGREE
Business-specific AML policy; KYC, enhanced due diligence and screening procedures; Ownership and escalation matrix.
02KYC, KYB & identity verification
Experience designing KYC systems from scratch.
Review journeys, verification criteria, vendors and handoffs between product and operations.
POTENTIAL DELIVERABLE · SCOPE TO AGREE
Risk-proportionate verification flows and practical team guidance.
03Fraud & transaction monitoring
Separate signal from noise.
Analyze patterns, calibrate alerts with real data and assess signal quality.
POTENTIAL DELIVERABLE · SCOPE TO AGREE
Explainable rules and triage playbooks to support decisions.
04Investigations & operations design
Bring method to difficult decisions.
Playbooks for account takeover, synthetic identities and abuse, with case reviews and team coaching.
POTENTIAL DELIVERABLE · SCOPE TO AGREE
Consistent investigations, organized evidence and escalation criteria.
05Zero-cost automation and applied AI
Rules, integrations and the Claude API, tailored to the task.
Monitoring, alerts and integrations using SQL and business rules. Zero execution cost options within free tiers and Claude API automation with human review and an agreed usage budget.
POTENTIAL DELIVERABLE · SCOPE TO AGREE
Workflows suited to the company’s volume and infrastructure, with documentation, review criteria and predictable operating costs.
06Operational assessment & readiness
Know what to fix first.
Gap analysis, process reviews and improvement prioritization for growing operations.
POTENTIAL DELIVERABLE · SCOPE TO AGREE
An action plan with sequencing, ownership and review criteria.
04 / PROJECTS & RESULTS
From hypothesis to
production controls.
Projects showing how I connect analysis, engineering and operations. Customer data and sensitive details are withheld; figures relate to the contexts described.
HOW I APPROACH MY WORK
“Identifying risk is not enough.Christiane Delazeri
You need to build the operation
that can respond to it.”
Experience in operations reaching 180 countries.
Experience structuring compliance and fraud prevention programs for international operations reaching 180 countries. At Deriv, responsible for developing the complete KYC manual and establishing the operations-side fraud prevention program. Expertise translating regulatory requirements into policies, procedures and operational controls, including Brazilian and US contexts.
REGULATORY EXPERIENCE
From regulatory requirements
to working controls.
Compliance and fraud programs need to reflect the risks, products and jurisdictions of an operation. My work connects these requirements to KYC, monitoring, investigations, documentation and automation.
FATF / GAFI
International standards
The FATF Recommendations guide risk-based approaches, customer and beneficial-owner due diligence, monitoring and suspicious activity handling. Their application depends on each jurisdiction’s laws.
Official source ↗United States
BSA / AML · FinCEN
The Bank Secrecy Act and its implementing regulations in 31 CFR Chapter X establish recordkeeping, reporting and control obligations for covered businesses. Operational design considers the institution category, including specific rules for casinos and money services businesses.
Official source ↗Brazil
AML/CFT · COAF · sector rules
Law 9,613/1998 underpins anti-money laundering prevention and duties for covered entities, including identification, recordkeeping and reporting to COAF. Regulatory classification determines which controls and procedures apply to the operation.
Official source ↗PEP, sanctions and adverse media require distinct analysis.
PEP status calls for proportionate due diligence; it is not an allegation or a sanction. Adverse media requires source and context assessment. Sanctions require identifying the applicable list and program: OFAC maintains the SDN List and consolidated non-SDN lists, whose restrictions are not identical.
Brazilian references by activity
Central Bank-supervised institutions
BCB Circular 3,978/2020: policy, risk assessment and controls to prevent money laundering and terrorist financing for covered institutions.
Fixed-odds betting
Law 14,790/2023 and SPA/MF Ordinance 1,143/2024: the betting framework and sector-specific AML/CFT requirements, including identification, monitoring and reporting procedures.
Virtual asset service providers
Law 14,478/2022 and BCB Resolution 520/2025: the virtual asset services framework and operational, governance and AML requirements, subject to classification and current rules.
Personal data in KYC and investigations
LGPD — Law 13,709/2018: legal bases, purpose, necessity and security in personal data processing. Collection and retention must be consistent with applicable obligations.
In practice: turn due diligence, risk classification, PEP and sanctions criteria into review workflows, approval levels, evidence and escalation paths. Fraud prevention and AML/CFT share data and controls, but have distinct objectives and obligations.
Selected references; applicability is assessed by activity, license and jurisdiction together with the business’s legal team. Regulatory content checked in September 2026.
05 / HOW I WORK
Strategy, implementation
and knowledge transfer.
Understand the project
Review the product, operating markets, existing documentation, tools and purpose of the engagement.
Define the proposal
Agree on scope, deliverables, timeline, responsibilities and acceptance criteria before work begins.
Build and validate
Develop policies, procedures or controls with review checkpoints and validation by the responsible team.
Deliver and support
Document decisions, enable the team and agree on post-delivery reviews and support within the contracted scope.
TOOLS THAT SUPPORT CONTROL
SQL · n8n · Cloudflare Workers · APIs and webhooks · Slack · Chatwoot · Claude API
FREQUENTLY ASKED QUESTIONS
Before we start.
Does consulting include technical implementation?
Yes. Scope can combine assessment, control design, SQL, integrations, automation, documentation and team training. Deliverables depend on the problem and the company’s tools.
Do you work with casinos and exchanges?
Yes. My focus includes casino and iGaming operators, crypto exchanges, fintechs and payment businesses. The work centers on AML, KYC, fraud prevention and operational efficiency.
Does the solution have to use AI?
Business rules, SQL and API integrations for monitoring, data enrichment and alerts. Zero execution cost where volume and architecture fit entirely within free infrastructure tiers, without token consumption. I also develop intelligent automation through the Claude API for text analysis, evidence organization and investigation support, with human review and usage controls. These projects incur API usage charges. Zero cost for eligible solutions refers to execution, not consulting fees or maintenance.
How does an engagement start?
Prepare your brief below and send it through LinkedIn. We discuss your project to define scope, deliverables and timeline for a tailored proposal.
06 / LET’S TALK
Tell me about your project.
Let’s define the scope.
Prepare your brief below and send it through LinkedIn. We discuss your project to define scope, deliverables and timeline for a tailored proposal.
Request a proposal on LinkedIn