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DAMANN Sp. z o.o.

Financial Crime & Regulatory Compliance · AI Governance

Fighting financial crime effectively. Implementing regulation with confidence.

DAMANN Sp. z o.o. advises on Financial Crime & Regulatory Compliance and on Strategic AI Consulting & AI Governance. We understand regulatory requirements – and implement them technically and operationally.

For banks, fintechs and payment companies

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Practice

Financial Crime & Regulatory Compliance

Advisory on combating financial crime and on regulatory compliance for banks, fintechs and payment companies – from resolving existing backlogs and assessing new requirements to processes and controls that work reliably in day-to-day operations.

Regulatory framework

  • AMLRRegulation (EU) 2024/1624 · largely applies from 10 July 2027
  • AMLARegulation (EU) 2024/1620 · seat in Frankfurt am Main
  • TFRRegulation (EU) 2023/1113
  • PSD2Directive (EU) 2015/2366
  • AML/KYC remediation

    Resolving backlogs and quality issues in customer data and due diligence – prioritised by risk and cleanly handed over to business-as-usual operations.

  • AML/KYC transformation

    Evolving the target picture, processes, roles, controls and system support in anti-money laundering – in line with the existing organisation.

  • AMLR/AMLA implementation

    Analysing impact and gaps, deriving a prioritised roadmap and translating the requirements into policies, processes and controls – with an eye on the new EU supervision.

  • Payments compliance

    Assessing the requirements of PSD2, the future PSD3/PSR and the Transfer of Funds Regulation (TFR) and translating them into compliant payment processes and controls.

Practice

Strategic AI Consulting & AI Governance

We support banks, fintechs, payment companies and other regulated companies in using artificial intelligence – with clear priorities, sound governance and an eye on the requirements of the EU AI Act.

Regulatory framework

  • AI ActRegulation (EU) 2024/1689 · staggered application from 2025
  • AI strategy and use-case prioritisation

    Clarifying goals, assessing use cases by benefit, feasibility and risk, and translating them into an actionable roadmap.

  • AI governance frameworks

    Roles, policies and decision paths for the use of AI – with an overview of the AI systems and their risk classification.

  • AI Act implementation

    Assessing the requirements of Regulation (EU) 2024/1689 for your AI systems and planning implementation along the staggered deadlines.

  • Integration with compliance

    Embedding AI governance in existing compliance, risk and control structures instead of building it alongside them.

Approach

Structured from target picture to day-to-day operations

Three competencies, one goal: understanding regulatory requirements and implementing them technically and operationally.

  • Regulation

    Assessing AMLR/AMLA, TFR, PSD2 and the AI Act, carrying out gap analyses and revising policies.

  • Data & technology

    Requirements and functional specifications, data logic and mappings (ISO 20022, SWIFT), SQL and Python analyses, model validation and testing, dashboards.

  • Operational delivery

    Designing processes and controls, testing them functionally and supporting them through go-live into day-to-day operations.

How we proceed

  1. Analysis

    Analysis and assessment

    Clarifying the starting point, impact and objectives – grounded in expertise and focused on what is achievable.

  2. Strategy

    Target picture and roadmap

    Assessing options, setting priorities and translating them into an actionable roadmap.

  3. Project management and transformation

    Delivery and steering

    Planning and steering initiatives – with transparent status, clear decisions and a reliable cadence.

  4. Organisation

    Embedding in daily operations

    Designing structures, processes, roles and controls so that results hold up in business-as-usual operations.

ProjectsFinancial Crime & Regulatory Compliance

Payments migration to agree21

Cooperative central bank · Payments
  • ISO 20022
  • SWIFT MT/MX
  • SEPA
  • EBICS
  • SQL
  • Tableau
Starting point
Multi-year migration of payments processing to the agree21 core banking system, with a focus on cross-border payments.
Our contribution
Requirements analysis, user stories and IT functional specifications, data logic and mapping rules for ISO 20022, SEPA, SWIFT MT/MX and EBICS, and functional testing through to go-live, backed by SQL-based data analysis.
Outcome
Documented functional specifications and mapping rules as the basis for implementation, and processes functionally tested through to go-live.

ProjectsFinancial Crime & Regulatory Compliance / AI Governance

Model risk governance for financial crime models

Major German private bank · Financial Crime · 1st Line of Defence
  • Sanctions screening
  • Random forest
  • Fuzzy matching
  • Levenshtein
  • Tableau
  • Power BI
  • Python Dash
Starting point
The model risk governance function for financial crime had to be built from the ground up, while numerous findings on transaction monitoring and screening models remained open.
Our contribution
Set-up of the governance function and its frameworks, remediation of critical sanctions screening findings through changes to TM, NLS and transaction filtering, documentation of model assumptions, sensitivity analyses and below-the-line testing.
Outcome
A governance function with frameworks in place, documented model assumptions and implemented changes addressing the critical findings.

ProjectsFinancial Crime & Regulatory Compliance

Preparing for the EU AML package

EU head office of a Japanese bank with several EU branches · Financial Crime · 2nd Line of Defence · Governance & Strategy
  • AMLR
  • AMLD6
  • TFR
  • AMLA
  • IRA/FCRA
Starting point
The head office and its branches had to prepare for the new EU AML package and revise the financial crime risk assessment methodology, while the governance function was still being set up.
Our contribution
Gap analyses of the AMLR, AMLD6 and TFR against policies, processes and IT, end-to-end management of the AMLA data collection exercises, tracking of findings through to closure, and revision of the AML/CFT policies and the institutional risk assessment, including its methodology.
Outcome
Prioritised actions from the gap analyses, findings tracked through to closure, and revised policies and risk assessment methodology.

ProjectsFinancial Crime & Regulatory Compliance

Licence change to credit institution and new products

European payments fintech · Regulatory Compliance · Germany, Austria, Netherlands
  • Licence change
  • Go/no-go
  • Product launch
  • DE · AT · NL
Starting point
Regulatory support for the move from a payment institution licence to a credit institution licence and for the launch of new products in Germany, Austria and the Netherlands.
Our contribution
Go/no-go recommendations on new product features covering regulatory classification and implementation requirements, and a regulatory assessment of the requirements arising from the licence change, their impact on the existing product range and the potential for new products.
Outcome
Documented recommendations as a basis for decisions on new product features and a country-by-country overview of the licence change requirements and their impact on the product range.

Contact

Let’s talk about your initiative.

Whether it is a specific regulatory requirement, an ongoing transformation or first questions about using AI – an initial conversation will clarify where we can support you.

We look forward to hearing from you. The quickest way to reach us is by email.