Legal & Compliance Support

Legal & Compliance Support

SK Consult provides practical legal and compliance support for cross-border businesses—contracts, governance, and documentation built with precision.

Note: where local legal advice is required, coordinated via trusted counsel.

Scope of services

Commercial contracts + negotiation support

Corporate governance

Compliance documentation frameworks (AML/KYC policies, onboarding, monitoring logic as required)

Ongoing support

Compliance is not a folder of policies. It is whether the business can explain itself

Every cross-border business eventually meets someone who will not take its word for anything: a bank reviewing the account, a supervisor reviewing the licence, an acquirer reviewing the data room, a counterparty reviewing the contract before signing. What each of them is testing is the same thing — whether the documents describe the business that actually exists, and whether the people running it can account for how it works. Businesses that can do this pass. Businesses with a well-drafted policy suite that nobody follows do not.

That is the standard we build to. Contracts that reflect the commercial deal rather than a template someone found; governance that produces a decision trail a third party can follow; AML and onboarding frameworks calibrated to your real customers, geographies and payment flows rather than to a generic risk universe. The test we apply to everything we draft is simple: if a regulator, a bank or a buyer asked for this file tomorrow, would it help you or expose you?

SK Consult provides this support on an ongoing basis for groups operating across the EU, the UK, the UAE and offshore jurisdictions — including regulated entities, payment and crypto businesses, and holding structures where the compliance perimeter runs across several countries at once. Where local law advice is required, we coordinate it through trusted counsel in the relevant jurisdiction and remain accountable for the result.

What the engagement covers

Mandates are scoped to what the business actually needs, but these components recur across almost every ongoing engagement.

01

Commercial contracts and negotiation support

Supply, distribution, agency, SaaS and licensing agreements, service and processing agreements, NDAs and term sheets. Drafted, reviewed and negotiated with attention to the clauses that decide outcomes in a dispute: liability, termination, governing law, dispute resolution and the definition of what was actually promised.

02

Corporate governance and decision trail

Board and shareholder resolutions, delegation of authority, conflict-of-interest handling, signing matrices and minute-keeping that demonstrates decisions were taken by the right people in the right place — the point supervisors and tax authorities examine when substance is questioned.

03

Shareholder and founder arrangements

Shareholders' agreements, reserved matters, deadlock and exit mechanics, vesting, drag and tag rights, and the interaction between the agreement and the constitutional documents of the company. Drafted before the disagreement, not during it.

04

AML/CFT and KYC frameworks

Business-wide risk assessment, customer risk scoring, onboarding and enhanced due diligence procedures, source-of-funds and source-of-wealth methodology, sanctions and PEP screening, transaction monitoring logic, escalation and reporting lines, and record-keeping standards.

05

Data protection and GDPR

Records of processing, privacy notices, lawful basis analysis, data processing agreements, international transfer mechanisms, retention schedules, breach response procedure and the practical question of who in the organisation actually owns each of them.

06

Regulatory monitoring and impact assessment

Tracking the regimes that apply to your activity, translating each change into a concrete action list with owners and deadlines, and telling you plainly when a change does not affect you — which is at least as valuable.

07

Policy and procedure maintenance

Annual review cycle, version control, evidence of board approval, staff training records and the audit trail that shows the framework is live rather than dormant. Supervisors ask for this more often than they ask for the policy itself.

08

Third-party and outsourcing arrangements

Vendor due diligence, outsourcing registers, exit plans and the contractual terms regulated entities are now required to impose on ICT and critical service providers.

09

Audit, inspection and information-request support

Preparation for supervisory visits, bank periodic reviews and buy-side due diligence: assembling the file, rehearsing the explanation, and answering requests precisely and on time.

Who this is for

Groups without an in-house legal function

Businesses at the stage where contract volume, counterparty scrutiny and regulatory exposure have outgrown ad-hoc external advice, but a full in-house team is not yet justified.

Regulated and payment businesses

Licensed entities, EMIs, PSPs, crypto-asset service providers and their groups, where the compliance framework is examined by a supervisor and by every banking partner in the chain.

Businesses preparing for scrutiny

Companies approaching a fundraise, a sale, a bank onboarding, a licence application or a first supervisory inspection, where the documentation has to withstand a reader who is looking for problems.

How the work runs

  1. Legal and compliance health check

    1–2 weeks

    Review of the existing contract stack, corporate records, policy suite and regulatory perimeter. Output: a written findings list ordered by exposure, separating what is urgent from what is merely untidy.

  2. Remediation plan

    1 week

    A prioritised plan with owners, sequencing and realistic effort estimates, agreed with you before drafting begins so the budget goes to the items that actually carry risk.

  3. Drafting and implementation

    3–10 weeks

    Contracts, corporate instruments, policies and procedures produced, reviewed with the responsible people, approved at board level where required, and put into use rather than filed.

  4. Embedding and training

    1–3 weeks

    Walkthroughs with the people who have to operate the framework day to day, decision templates, escalation guidance and the evidence trail that shows training took place.

  5. Ongoing support

    continuing

    Named contact for day-to-day questions, contract review as deals arise, regulatory change monitoring, annual policy review and support during audits, inspections and information requests.

Timelines are indicative and depend on the state of the existing documentation, the number of entities in scope and the responsiveness of internal stakeholders. Where local law advice or a local filing is required, it is coordinated through counsel in the relevant jurisdiction.

The regimes that currently drive compliance workload

This is the live picture as at July 2026. Dates move, and several of these are still in transition — which is exactly why monitoring is part of the engagement rather than an afterthought.

Regime Status and key date What it means in practice
EU AML package (AMLR, AMLD6, AMLA) AMLA operational since 1 July 2025; AMLR and AMLD6 apply from 10 July 2027 A single directly applicable rulebook replaces much of the national patchwork, and beneficial ownership is harmonised at a threshold of 25% or more. Frameworks built against national guidance will need to be re-mapped, and groups operating in several member states lose the ability to run materially different standards in each.
DORA (digital operational resilience) Applicable since 17 January 2025 Financial entities — including payment institutions, EMIs and crypto-asset service providers — must maintain an ICT risk framework, a register of information on ICT third-party arrangements, incident reporting, resilience testing and contractual terms with critical providers. The register, not the policy, is what supervisors ask for first.
MiCA (crypto-asset services) Transitional period ended 1 July 2026 Serving EU clients with crypto-asset services without a CASP authorisation is a breach rather than a grey area. For authorised firms the workload has shifted to ongoing conduct, disclosure, safeguarding and reporting obligations.
PSD3 and PSR Political agreement November 2025; adoption expected during 2026, application anticipated late 2027 The separate e-money regime disappears and EMIs become a sub-category of payment institutions subject to re-authorisation. Fraud rules tighten, including payee name and IBAN matching and reimbursement obligations for authorised push payment fraud. Preparation belongs in the 2026–2027 plan, not in 2027.
GDPR In force; enforcement focused on transfers, retention and dark patterns The recurring failures we see are not missing privacy notices but absent records of processing, unmanaged processor chains, undocumented international transfers and retention periods nobody applies.
EU AI Act Prohibitions and AI literacy since 2 February 2025; GPAI rules since 2 August 2025; high-risk obligations deferred by the Digital Omnibus adopted 29 June 2026 to 2 December 2027 (stand-alone) and 2 August 2028 (embedded in products) The high-risk deadline moved, but the prohibitions, transparency duties and AI literacy obligations did not. Businesses using AI in onboarding, scoring or monitoring should map their systems now, while the deferral provides room to do it properly.
NIS2 (cybersecurity) Transposition was due 17 October 2024; the Commission referred Ireland, Spain, France and the Netherlands to the Court of Justice on 8 July 2026 Obligations arrive through national law, so the practical requirements and the enforcement start date still differ by country. Groups operating in several member states need a per-country view rather than a single EU-wide assumption.

What actually decides the outcome

Documents must match the business

The most damaging finding in any review is not a missing policy — it is a policy that describes a different company. Where the written framework and the observed practice diverge, the divergence itself becomes the finding.

Ownership inside the organisation

Every procedure needs a named person who performs it and a named person who checks it. Frameworks that belong to "compliance" in the abstract are the ones that quietly stop being operated.

Evidence, not intention

Screening performed but not logged, training delivered but not recorded, approvals given verbally: in a review, none of these happened. The record is the control.

Proportionality works both ways

A framework too heavy for the business is abandoned within a quarter; one too light fails the first serious review. Calibration to actual products, volumes and geographies is the whole exercise.

Contracts are read when relationships fail

The clauses that matter are the ones nobody negotiates while everyone is optimistic — liability caps, termination triggers, IP ownership, data responsibilities and where a dispute is heard.

The group perimeter, not the entity

Supervisors, banks and buyers look at the whole structure. A weak entity in the chain becomes a question about every other entity, regardless of where the regulated activity sits.

Where legal and compliance work goes wrong

  • A downloaded policy suite adopted without mapping it to the actual products, customer geographies and payment flows — visible to any reviewer within minutes.
  • Corporate records that stop shortly after incorporation, leaving no decision trail to demonstrate where management actually sits.
  • Contracts signed on the counterparty's paper because the deal was urgent, with liability and termination terms nobody read until they mattered.
  • A shareholders' agreement postponed to "after the raise", then negotiated during the first serious disagreement between founders.
  • Onboarding files that record the documents collected but not the reasoning applied — the assessment, not the passport copy, is what a supervisor tests.
  • Treating GDPR as a website notice exercise while processor chains, transfers and retention go undocumented.
  • Assuming an EU-wide regime applies uniformly when it arrives through national transposition, as NIS2 does, and where several member states are still late.
  • Discovering during a bank review or a data room that policies were never board-approved, never versioned and never trained on.

What we typically need from you

Providing this at the outset materially shortens the health check and produces a sharper findings list.

  • Group structure chart and the ownership chain up to the ultimate beneficial owners
  • Constitutional documents, statutory registers and corporate records for each entity in scope
  • Existing shareholders' or founders' agreements and any side letters
  • The current contract stack — templates in use and material signed agreements
  • Existing policies, procedures and manuals, with their approval and version history
  • Description of products, customer segments, target geographies and distribution channels
  • Payment architecture: banking, EMI and PSP arrangements and the flow of funds between them
  • Any licences held, regulatory correspondence, inspection findings or remediation plans
  • List of material third-party and outsourcing providers, including ICT and cloud services

What drives cost and timeline

Ongoing support engagements vary widely in effort. These are the variables that account for most of the difference.

  • The number of entities and jurisdictions inside the compliance perimeter
  • Whether the business is regulated, and by how many authorities
  • The condition of the existing documentation — remediation is usually slower than drafting from zero
  • Contract volume and how much of it is negotiated rather than issued on your own template
  • The complexity of the payment architecture and the number of third-party dependencies
  • Whether an external deadline is driving the work: a licence application, a bank review, a fundraise or a sale
  • Internal responsiveness — the availability of the people who hold the facts is consistently the largest variable

Frequently asked questions

Do you replace our lawyers, or work alongside them?

Both arrangements are common. For groups without an in-house function we act as the standing legal and compliance resource. Where in-house counsel or local firms are already engaged, we typically take the cross-border and regulatory workstream and coordinate the rest. Where local law advice or a local filing is required, it is provided through trusted counsel in that jurisdiction, and we remain accountable for the overall result.

We already have AML policies. Why would they need rewriting?

Often they do not — they need calibrating. The frequent problem is not the absence of a manual but the absence of a link between the manual and the business: risk scoring that does not reflect actual customer geographies, monitoring rules that do not match real payment patterns, and enhanced due diligence triggers copied from a different business model. That gap is what a reviewer finds, and it is usually correctable without starting again.

How is ongoing support priced?

Most clients use a monthly retainer covering an agreed scope — day-to-day questions, contract review up to an agreed volume, regulatory monitoring and annual policy review — with defined projects such as a licence application or a remediation programme quoted separately. Scope and price are agreed in writing before work begins, and we would rather resize the retainer than let it drift.

What does the AI Act deferral mean for us?

The Digital Omnibus adopted by the Council on 29 June 2026 postponed the high-risk obligations to 2 December 2027 for stand-alone systems and 2 August 2028 for systems embedded in regulated products. What did not move are the prohibitions and AI literacy duties applicable since 2 February 2025 and the general-purpose AI rules applicable since 2 August 2025. If you use AI in onboarding, credit or risk scoring, transaction monitoring or customer communications, the sensible use of the deferral is to complete the system inventory and classification now rather than to defer the question.

Our business is not regulated. Does any of this apply?

Some of it will. GDPR applies to almost every business handling personal data, sector rules can reach unregulated firms through their regulated counterparties, and banks apply their own compliance expectations to customers regardless of licensing status. Part of the health check is telling you which regimes genuinely apply and which do not — the second list is often longer than clients expect.

Can you help during a supervisory inspection or a bank review?

Yes, and this is a significant part of the practice. We assemble the file, prepare the people who will answer questions, draft the responses and manage the timetable. The single most common avoidable failure at this stage is answering imprecisely or late; both are read as weakness in the control environment rather than as administrative slippage.

How quickly can you start?

A health check can usually begin within a week of engagement, and urgent items — a contract on the table, an information request with a deadline — are picked up immediately. Full remediation of a neglected framework across several entities is a matter of months rather than weeks, which is why the plan is sequenced by exposure rather than attempted in one pass.

This page describes SK Consult services and general practice. It is not legal advice and does not create a client relationship. Regulatory requirements change and are applied to specific facts; any decision should be taken on advice addressing your own circumstances.

Contact us

If you need practical legal and compliance support for cross-border operations, please get in touch with a brief overview of your business model, the jurisdictions involved, and your key counterparties—such as banks, EMIs, PSPs, or other partners. Based on that information, a proposed scope of work and recommended next steps can be provided.

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