Resilience Group
Home Who We Serve What We Do Why Gibraltar Insights About Contact

What We Do · Compliance & AML

Outsourced compliance that survives a GFSC inspection.

Gibraltar entities subject to AML/CFT obligations need robust compliance procedures, trained staff, and ongoing monitoring. Resilience Group provides outsourced compliance support — KYC onboarding, transaction monitoring, MLRO services, and substance and governance advisory — backed by the same regulatory framework the GFSC inspects us under.

Scope

What this service covers

Four core compliance services. Most clients combine MLRO with onboarding and monitoring; substance advisory is provided on a project basis.

AML/KYC onboarding

Customer due diligence for new clients and investors — identity verification, source of wealth and funds checks, enhanced due diligence for higher-risk relationships, and PEP screening.

Ongoing monitoring

Transaction monitoring, periodic review of existing relationships, sanctions screening, adverse-media checks, and trigger-based escalation for material changes.

MLRO services

Outsourced Money Laundering Reporting Officer for entities that need a qualified MLRO without an in-house hire. Internal SAR assessment and external reporting to the GFSC where required.

Substance, governance, policy

Advisory on economic-substance requirements, governance structures, and regulatory expectations; drafting and maintaining AML/CFT policies, risk assessments, and compliance manuals tailored to the business.

For Whom

Who this service is for

Compliance support is relevant where the regulatory exposure is real but an in-house team is not yet justified.

GFSC-regulated entities without in-house compliance

Small fund managers, CSPs, and trust companies that need a documented compliance function and qualified MLRO without making a senior hire.

Read the Fund Managers hub →

Non-regulated entities with AML obligations

Company service providers, tax advisers, and other businesses with AML obligations under the Proceeds of Crime Act who need policies, procedures, and ongoing monitoring.

Read the Corporate hub →

International groups with Gibraltar subsidiaries

Groups whose head office runs compliance globally but need locally knowledgeable input on Gibraltar requirements, substance, and GFSC expectations.

Read the Intermediaries hub →

What We Won't Do

Where we draw the line

Explicit scope-exclusion is more useful to a serious client than another positive claim. Here is what we will not take on.

We don't take engagements where the client cannot or will not meet substance requirements.

Outsourced compliance is accepted by the GFSC, but the regulated entity remains ultimately responsible for compliance and for the substance of its Gibraltar presence. We will not accept a mandate where the client expects compliance to be a paper exercise covering activity that has no real Gibraltar nexus. Where substance is thin, we say so before engagement — and either help fix it or decline.

Process

How an engagement works

Four phases. Click a step to expand it.

Step 01 Compliance healthcheck

We review existing AML policies, procedures, risk assessments, customer files, and training records against current regulatory expectations. The output is a gap report — what works, what needs strengthening, and what is missing entirely.

Step 02 Proposal and engagement

Detailed proposal covering scope (MLRO, onboarding, monitoring, policy), the named officers responsible, the reporting cadence, and the regulated entity's retained responsibilities under the outsourcing arrangement.

Step 03 Implementation

Policies and procedures put in place, staff trained, MLRO appointment formalised, and the regulatory calendar handed across. Where the engagement starts mid-cycle, we close any gaps in the current period before going live.

Step 04 Ongoing service

Routine onboarding and monitoring, quarterly MI to the regulated entity's board, annual policy review, and inspection support if and when the GFSC visits. A named compliance officer is responsible throughout.

The Team

Who delivers this service

Named professionals responsible for this practice. Photographs and full bios on Our People.

Elena Marquez (placeholder)

Director, Compliance

ICA DiplomaCAMS

Leads the compliance practice. Acts as outsourced MLRO across regulated and non-regulated mandates.

Thomas Wright (placeholder)

Senior Compliance Officer

ICA

Onboarding, transaction monitoring, and the AML/CFT manual across the compliance book.

Daniel Moreno (placeholder)

Fund Compliance Officer

ICA

Fund-side compliance — investor AML, ongoing monitoring, GFSC regulatory calendar.

Names shown above are placeholders pending the Sprint F About-page roster review. Final names will be confirmed before launch.

Need compliance support?

From a healthcheck to a full outsourced compliance function, an initial conversation will tell you what the regulator expects and what it would take to get there.

Last reviewed: May 2026