AI-NATIVE INFRASTRUCTURE FOR FINANCIAL-CRIME COMPLIANCE · SERIES A–B FCA-AUTHORISED & PRE-AUTHORISATION FINTECHS · AML · UBO · SANCTIONS SCREENING · SAR DRAFTING · EVIDENCE PACKS

AI-native infrastructure for
financial-crime compliance
— the MLRO always signs off.

Financial crime compliance is the obligation that carries personal, criminal liability for the MLRO — from the day a firm applies for authorisation, not the day it is granted. VIRGIL is the infrastructure your compliance function runs on — wired directly to your transaction data, your regulatory stack and your risk appetite, not a generic dashboard bolted on top. It investigates transaction monitoring alerts, screens sanctions, PEP and UBO exposure, and drafts SAR narratives with full evidence provenance, tailored to how your fintech actually operates. We prepare, draft and evidence; your MLRO reviews and signs off. Nothing is filed without a human.

FCA enforcement actions are up 43% in the past 24 months, and alert volumes keep rising against compliance teams of one to three. VIRGIL investigates the alert, evidences the decision and drafts the SAR — every conclusion traced to its source transaction, so the record survives an FCA s166 review.

Book a Demo See How It Works
What We Do For You

Infrastructure wired to
your workflow, not a template.

VIRGIL connects to your transaction data, runs a six-agent consensus engine built on documented AML and financial crime failure patterns, and drafts SARs, alert rationales and evidence packs mapped to your regulatory stack — POCA 2002, MLR 2017, JMLSG guidance, FCA SYSC 6.3, the OFSI sanctions regime and the NCA SAR/DAML regime — configured around how your fintech actually operates, so your team reviews and submits, never drafts from scratch.

F-001
Compliance automated. No manual assembly required.

VIRGIL monitors your transaction stream and infrastructure posture, scores anomalies, and generates regulatory reports automatically. Your compliance team focuses on decisions and sign-off — not pulling data, writing SARs, or formatting audit packs.

DATA → SCORE → REPORT → SIGN-OFF
F-002
High-accuracy AML detection — built on documented failure signatures

The agent engine is built on documented AML and financial crime failure patterns — the specific pre-event signals in transaction velocity, structuring behaviour, and counterparty patterns. Six agents vote in consensus before any alert is escalated, filtering low-risk alerts for human confirmation and cutting false-positive review time.

AML FAILURE SIGNATURES · 6-AGENT CONSENSUS
F-003
SAR drafts in one click. FCA-ready.

Compliance analysts spend 60–70% of their week manually drafting SARs. VIRGIL Copilot generates complete Suspicious Activity Report drafts mapped to FCA requirements, ready for MLRO review and submission — in a single click.

ONE-CLICK SAR · FCA-MAPPED · MLRO READY
F-004
Your financial crime obligations, evidenced continuously

POCA 2002, MLR 2017, JMLSG guidance, FCA SYSC 6.3, the OFSI sanctions regime and the NCA SAR/DAML regime — the regulatory stack your fintech answers for, evidenced as you work each alert. VIRGIL keeps the record a supervisor can read.

POCA 2002 · MLR 2017 · JMLSG · SYSC 6.3 · OFSI
F-005
Audit evidence packs — ready for your next supervisory visit

VIRGIL generates timestamped, event-level evidence bundles mapped to your regulatory stack — a decision trail per alert and SAR, structured for FCA s166 reviews, REP-CRIM support and sponsor-bank reporting.

AUDITABLE · s166-READY · REP-CRIM
F-006
Free gap report. Live in under 48 hours.

Read-only API connection. 48 hours. VIRGIL delivers a detailed report showing your top 5 financial crime blind spots against your regulatory obligations — MLR 2017 monitoring, sanctions screening, SAR readiness and evidence gaps. No sales call required.

FREE GAP REPORT · READ-ONLY · ZERO DISRUPTION
Inside the platform
The Command Center your
compliance team works in.

Live readiness scores, AI-ranked actions, a regulatory-intelligence feed, a risk heatmap, evidence coverage, AML anomaly detection and one-click SAR drafts — every obligation tracked in one workspace.

Executive Summary
VIRGIL Executive Summary — financial crime posture and FCA, AML and SAR readiness scores with AI-recommended actions
Recommended Actions
VIRGIL Recommended Actions — highest-impact compliance gaps ranked by readiness-score impact
Regulatory Intel
VIRGIL Regulatory Intel — FCA, ICO and EBA updates scored by impact on your controls
Risk Center
VIRGIL Risk Center — likelihood-by-impact risk heatmap and risk register
Evidence Center
VIRGIL Evidence Center — control-by-control evidence freshness, coverage and gaps
SAR Drafts
VIRGIL SAR Drafts — AI-generated, FCA-ready Suspicious Activity Report drafts queued for MLRO review
Team
VIRGIL Team — per-member seats, each signing in with their own API key
Anomalies
VIRGIL Anomalies — AI-flagged suspicious transactions with confidence scores, severity and network-risk analysis
“

Impressive — you didn't just bolt an LLM on a problem. You understood where AI shouldn't be trusted and forced every SAR draft through human review. That's the judgment that separates compliance experts from armchair theorists.

VP
Vatsal Pareshkumar
Founder · OutputLens
What VIRGIL Actually Does

Four things, done precisely
— tailored to your workflow.

VIRGIL is scoped deliberately. We don't bolt on identity verification to look like a full KYC suite — no document capture, no biometric processing, no IDV provider — we configure these four around your transaction data, your regulatory stack and your risk appetite. That's the operation. See who we build it for.

01
Transaction monitoring & AML anomaly detection

A six-agent consensus engine scores your transaction stream against documented AML failure patterns — velocity, structuring, counterparty risk — tuned to your product and risk appetite, not a generic ruleset.

02
Screening & KYC/KYB due diligence

Every counterparty is screened against sanctions, PEP and adverse-media sources, with beneficial ownership checked against Companies House. Customer and business onboarding is checked against MLR 2017 reg. 28 — every outstanding requirement quotes the provision it derives from, and every check is logged with a timestamp.

03
SAR / DAML narrative drafting for human review

A complete, FCA-mapped draft for every escalated alert — agent reasoning and evidence attached, queued for your MLRO to review and submit. VIRGIL never files.

04
Audit-evidence packs & control-readiness scoring

A timestamped, s166-ready trail per alert and SAR, mapped to the UK financial crime stack, with a live readiness score against your regulatory obligations.

VIRGIL Copilot — Inside Our Operation

The co-pilot our analysts
never work without.

VIRGIL Copilot is how our analysts and MLRO actually do the work — surfacing agent reasoning, triaging live alerts, and drafting SARs inside a single case view. You don't get a login to it. You get what it produces: reviewed, evidenced, ready to sign. We show it publicly because an outcome is only as good as the process behind it, and we don't ask you to take that on faith.

VIRGIL Copilot — a live FCA-compliant SAR draft with the six-agent reasoning panel (AML Review, UBO Verifier, Network Analyst, Policy Alignment, Predictive Forecast, Format & NCA Compliance)
SAR Draft in One Click

Copilot generates a complete, FCA-mapped Suspicious Activity Report draft from the flagged transaction data — with agent reasoning, counterparty analysis, and structured sections ready for MLRO review. One click. Under 60 seconds.

Agent Reasoning Visible

Every alert shows the full 6-agent consensus trace: which agents fired, what signals triggered them, and why. MLROs sign off on evidence, not black boxes — satisfying FCA explainability expectations out of the box.

Live Alert Triage

Alerts surface prioritised by severity, framework relevance, and velocity signal. Copilot filters low-risk alerts for human confirmation before they reach the MLRO queue — cutting false-positive review time while raising escalation quality.

Sanctions, PEP & UBO Screening

Copilot cross-references counterparties against sanctions and PEP lists and flags beneficial ownership not yet verified against Companies House — surfacing the enhanced-due-diligence gaps an MLRO must close before filing.

See Copilot in action

A 30-minute demo includes a live Copilot walkthrough on your specific regulatory obligations.

Book a Demo
Built For

Built for fintechs getting
— and staying — compliant.

We work with one kind of firm: Series A–B fintechs with 1–3 person compliance teams, either already FCA-authorised or preparing the application — where a missed SAR, a failed audit, a rejected application or a compliance gap surfaced in diligence carries deal-blocking, licence-risk consequences. We don't serve banks, later-stage groups or firms outside the FCA perimeter, and the product is sharper for it.

PRIMARY ICP
01
MLROs & CCOs at Series A–B Fintechs

Our beachhead. MLROs at FCA-authorised fintechs face personal liability under FCA MLRO Rules and supervisory visits rising 40% year-on-year. VIRGIL gives them a live, auditable compliance record — AML anomaly detection, SAR drafts, and evidence packs — that turns an overwhelmed 2-person team into a defensible compliance function.

Primary Beachhead · FCA-Authorised · EMI
02
CFOs & COOs at Series B Pre-Close

Compliance gaps surfaced during Series B due diligence kill deals. VIRGIL generates the audit trail and evidence packs that satisfy investor DD teams before they flag compliance as a deal risk. The trigger: a Series B round in the next 6 months with DD starting.

Deal-Risk Evidence
03
Firms Applying for Authorisation or Registration

Pre-authorisation is where most firms are weakest and most exposed: an FCA application, an EMI or payment institution variation, or a cryptoasset registration all turn on demonstrable AML systems and controls — not intentions. VIRGIL stands up the investigated alerts, sanctions/PEP/UBO screening logs and evidenced audit trail a case officer expects to see, so you apply with a working compliance function rather than a policy document.

Pre-Authorisation · EMI / API · MLR 2017
Why VIRGIL Wins

The moat is the
regulatory pattern library.

VIRGIL's agent engine is built on documented AML and regulatory failure patterns — the specific pre-event signals that precede regulatory action. That pattern library is the moat.

Read-Only, Evidence-First Architecture

VIRGIL connects by read-only API and never writes to your systems. Every conclusion carries its provenance — source transaction, rule triggered, agent reasoning, human sign-off — built for an FCA s166 review from day one.

End–to–End Encryption

Data encrypted in transit (TLS) and at rest (AES–256). Zero–plaintext policy for production systems handling transaction, KYC, infrastructure, and regulatory data.

Resilient Infrastructure

Automatic failover and continuous availability, with UK data residency available for FCA-authorised clients with jurisdiction-specific requirements.

Enterprise SLAs & DPA

Contractual SLAs, data processing addenda, and security exhibits aligned with FCA-authorised firm requirements and the diligence standards Series B investors and sponsor banks apply.

Regulatory Coverage

The financial
crime stack.

VIRGIL covers your entity's financial crime obligations — POCA 2002, MLR 2017, JMLSG guidance, FCA SYSC 6.3, the SMCR (SMF17), OFSI sanctions and the NCA SAR/DAML regime, with REP-CRIM data support. Continuously evidenced, with the trail to prove it.

R-001
POCA 2002 · Active

The Proceeds of Crime Act s.330 disclosure obligation — failure to disclose is a criminal offence. VIRGIL drafts the SAR narratives and evidences the disclosure decision for the MLRO to review and submit.

ACTIVE · s.330 DISCLOSURE
R-002
MLR 2017 · Active

The Money Laundering Regulations: risk-based ongoing monitoring, CDD and EDD. VIRGIL investigates alerts and produces the monitoring evidence and CDD/EDD rationale a supervisor expects to see.

ACTIVE · RISK-BASED MONITORING
R-003
JMLSG Guidance · Active

Joint Money Laundering Steering Group good practice. VIRGIL aligns its CDD/EDD rationale and counterparty write-ups to JMLSG, so the reasoning behind each disposition is defensible.

ACTIVE · CDD / EDD RATIONALE
R-004
FCA SYSC 6.3 · Active

Systems and controls against financial crime, and SMCR (SMF17) accountability. VIRGIL evidences that monitoring ran, that alerts were worked, and that decisions were recorded — the systems evidence SYSC expects.

ACTIVE · SYSC 6.3 · SMF17
R-005
OFSI Sanctions Regime · Active

Financial sanctions compliance. VIRGIL screens counterparties against sanctions and PEP exposure, flags UBO gaps against Companies House, and logs every check with a timestamp.

ACTIVE · SANCTIONS · PEP · UBO
R-006
NCA SAR / DAML · Active

Suspicious Activity Reports and Defence Against Money Laundering. VIRGIL drafts SARs and DAML requests for human review; the MLRO submits to the NCA. VIRGIL never files.

ACTIVE · SAR / DAML DRAFTING
FAQ

Frequently asked
questions.

Screening tools detect — they flag a name or a transaction and hand you an alert. VIRGIL investigates and evidences: it works the alert through a six-agent consensus review, writes the rationale for the disposition, drafts the SAR and keeps a timestamped trail for your s166 file. VIRGIL does financial crime only — no SOC 2, no operational risk, no security evidence. That focus is deliberate: a tool that tries to do every framework does none at the depth an FCA supervisor tests. It runs alongside your existing monitoring, and it's priced for Series A–B fintechs rather than banks with six-figure budgets.

VIRGIL Copilot is the interface our analysts and MLRO work inside — surfacing live alerts with full agent reasoning traces, generating SAR drafts, and exporting evidence packs, all in one case view. You don't get a login to it; you get what it produces, reviewed and signed off. See it demonstrated at any product demo.

No. VIRGIL automates the document assembly, report generation, and monitoring that currently consumes 60–70% of a compliance analyst's week. Your MLRO reviews SAR drafts via Copilot and submits them — they never draft from scratch. FCA MLRO Rules require personal sign-off; VIRGIL makes that sign-off faster and better-evidenced, not unnecessary.

Connect a read-only API, or upload your transaction data as CSV, Excel, or PDF. Within 48 hours, VIRGIL delivers a detailed report showing your top 5 financial crime blind spots against your regulatory obligations — MLR 2017 monitoring, sanctions screening, SAR readiness and evidence gaps. No sales call required, and no commitment attached.

VIRGIL connects by read-only API and never writes to your systems. Data is encrypted in transit (TLS) and at rest (AES–256), with least–privilege access controls, network segmentation and continuous monitoring. UK data residency is available for clients with jurisdiction-specific requirements. A Data Processing Addendum is available on request.

Book a Demo

See VIRGIL in action.

Book a 30-minute demo and we'll walk you through VIRGIL's AML detection, SAR generation via Copilot, and audit evidence capabilities using a live environment. Our team will respond within 24 hours.

Book a Demo — Pick a Time
WHAT TO EXPECT
Live Platform Walkthrough
See AML anomaly detection, Copilot SAR generation, and audit evidence packs on a live environment.
Your Use Case
We tailor the demo to your obligations — POCA 2002, MLR 2017, OFSI sanctions, SAR drafting, or sponsor-bank AML reporting.
Free Gap Report
Every demo includes a complimentary AML or infrastructure blind spot assessment — no commitment required.
30 Minutes. No Sales Pitch.
A focused technical walkthrough with our compliance engineering team. You leave with a clear view of how VIRGIL fits your stack.
Current Availability

Accepting demo requests for Q2 2026. Response within 24 hours.

DEMO REQUEST FORM

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P(SAR|D) ∝ P(D|SAR)·P(SAR) E[fine] = Σ p¹·F¹·(1−m) precision = TP / (TP + FP) risk = f(velocity, θ, counterparty) AML ∩ KYC ∩ OFSI
7EULERIANSTRATEGIES · ABOUT US FOUNDED 2025 · UK
ABOUT / 7EULERIANSTRATEGIES

Engineering
the compliance infrastructure
era.

We build and operate the AI-native infrastructure fintechs plug their financial-crime compliance function into — wired to your transaction data and regulatory stack, not a generic dashboard. VIRGIL continuously monitors transactions, detects AML anomalies, generates SARs via Copilot, and produces audit-ready evidence packs. Our regulatory pattern library is the moat.

The industry doesn't have a data problem. It has an automation problem — compliance signals arrive too late, too manually-processed, and too siloed to prevent regulatory action. We built VIRGIL to close that loop.

Kingston
University roots
Founded by engineering and research undergraduates united by a shared belief that fintech compliance deserves better tools and better outcomes.
Production–Grade
Engineering culture
Large–scale agentic AI systems, production data pipelines, and real–world regulatory exposure — from day one.
UK · EU · Global
Global ambition
Building the financial-crime compliance layer for UK fintechs holding — or applying for — an FCA authorisation.
Our Story

Regulatory compliance.
One pattern library.
One moat.

Every major regulatory failure follows a pattern. A suspicious transaction isn't flagged without warning signals — velocity spikes, structuring behaviour, counterparty anomalies. A compliance gap doesn't materialise overnight. The signals are there. The industry just wasn't processing them fast enough, or automatically enough, to act before the FCA did.

We documented AML and regulatory failure patterns — the specific pre-event signal sequences that precede regulatory action, failed audits, and licence revocations. Not from a generic dataset. From direct research and case-by-case analysis, extracting the compliance patterns that standard rule-based monitoring tools consistently miss.

That corpus is encoded into VIRGIL's agent engine and surfaced through Copilot. It is the reason VIRGIL catches compliance risks before they escalate.

We then wired that engine to transaction data streams, infrastructure monitoring, regulatory framework mappings, and SAR generation workflows. The result: a platform that detects AML anomalies, scores severity, generates regulatory reports, and compiles audit evidence — automatically, in under 48 hours.

WHAT WE STAND FOR
  • Engineering rigour
    Production–grade systems, not prototypes. We ship compliance automation that holds under real regulatory conditions.
  • Regulatory depth
    We understand POCA 2002, MLR 2017, JMLSG, FCA SYSC 6.3 and the SMCR from the inside. We know what an MLRO needs to sign off a SAR.
  • Automate before, not remediate after
    The industry is built on reactive compliance. We're building the infrastructure to shift it towards prevention.
  • Team over hierarchy
    We move fast because we trust each other. Decisions are made by people closest to the problem.
  • Craft meets impact
    We genuinely care about what we build — the accuracy of the agents, the precision of the SAR drafts, the clarity of the audit packs.
Founder

Mitual Sharma.
Founder, CEO & CTO.

Building AI-native compliance infrastructure for Series A–B UK fintechs inside — and entering — the FCA perimeter.

Most compliance failures are not surprises. The signals exist — in transaction velocity, counterparty behaviour, control gaps — long before a regulator acts. The industry's problem was never data. It was that the data arrived too late, too manual, and too disconnected to prevent the outcome.

His edge is the combination this market rarely holds in one person: AI systems engineering, regulatory operating knowledge, and product architecture. He builds the detection models, designs the agent consensus that makes their output trustworthy, and turns dense regulatory obligation into something a founder can act on in an afternoon — not a quarter.

Compliance should be invisible, automated, and on the founder's side — not a tax on building.

He started by building risk-prevention systems and kept hitting the same wall: compliance teams of one or two, expected to hold back obligations designed for departments. VIRGIL is the tool he wished those teams had — one that does the watching, drafting, and evidencing, so people can do the judgement.

VIRGIL is the financial crime engine for fintechs building or holding an authorisation — investigating, evidencing and drafting, so the MLRO can do the judgement.

WHAT HE LEADS
  • AI systems design
    The detection models and six-agent consensus that make AI-assisted compliance output something a team will trust and act on.
  • Product architecture
    From a transaction or infrastructure signal to an MLRO-ready SAR, audit pack, and live readiness score.
  • Regulatory intelligence
    Models that keep VIRGIL current as FCA, MLR 2017, sanctions and SAR obligations move — and tailored to each firm.
  • Commercial narrative
    How the platform works — and why it matters to the people who carry the regulatory risk.
The Founder

The person who built
the pattern library.

VIRGIL's moat is a documented corpus of AML and regulatory failure patterns. Building it required an AI engineer who understood anomaly detection at production scale, could wire transaction signals to real-world regulatory reports, and knew what those signals actually meant inside an FCA-authorised firm's compliance function — one person, one product, one regulatory domain.

MS
Mitual Sharma
Founder · CEO & CTO

Owns VIRGIL's technical direction and commercial narrative — the detection models, the 6-agent consensus, the product architecture, and the regulatory intelligence that keeps it current. AI engineering, regulatory operating knowledge, and product in one place.

Agentic AIProduct ArchitectureRegulatory Intelligence
Connect With Us Follow our progress at 7EulerianStrategies
Our Mission

Rigorous engineering.
Deep regulatory
understanding.

We exist to create AI that genuinely serves the people solving real–world compliance problems — MLROs, CCOs, compliance officers, and analysts buried in manual reporting obligations. Not another dashboard. An intelligence that acts, learns, and makes the regulatory function stronger every time it generates a report.

HOW WE'RE DOING IT
  • Agentic AI that closes the compliance loop
    Complete, evidenced regulatory outputs drafted in under 48 hours, from transaction signal to MLRO-ready SAR via Copilot — always for a human to review and submit.
  • Six agents working in consensus, not single bets
    Fewer false positives, stronger recall, and explainability that compliance teams and FCA supervisors can trust and evidence.
  • No new login for your team
    We don't ask your MLRO to learn a platform. VIRGIL Copilot is how our analysts work the case — you receive what it produces, delivered the way you already work.
  • Enterprise–grade from the start
    Read-only by default, end–to–end encrypted, UK data residency available. The security posture FCA supervisors expect — VIRGIL never writes to your systems and never files.
Work With Us

See what VIRGIL can do
for your compliance function.
Book a demo.

If you're an FCA-authorised fintech with a compliance obligation in the next 6 months — or preparing an authorisation or registration application and need the systems and controls to stand behind it — book a 30-minute demo and we'll show you exactly how VIRGIL and Copilot address your specific requirements.

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RESPONSE WITHIN 24 HOURS

Engagement Model

You don't buy software.
You engage an operation.

VIRGIL is AI-native financial-crime compliance infrastructure, not a pay-per-check vendor. Engage 7EulerianStrategies to run part — or all — of your financial crime function: a low fixed monthly fee buys unlimited access to the operation — monitoring, screening and drafting run continuously with MLRO-grade human oversight — and you pay separately, per unit, only for the compliance work we actually complete on your behalf. No seats, no licences, no hourly rates. You pay for results.

01 — Operational Retainer

Three tiers, one operation. Every tier is access to the same AI-native FCC infrastructure — continuous monitoring, screening, investigation and drafting, run by our analysts with MLRO-grade human oversight, at unlimited operational capacity and no volume caps. There is no software for your team to log into and no seats to license. The tiers differ in depth of oversight and support, not in what you're allowed to run — and the outcome-based pricing below sits on top of all three at the same fixed, predictable rates.

Retainer
Starter
£1,000/month
For early-stage FCA-authorised or pre-authorisation fintechs standing up financial-crime compliance without hiring a team.
  • Unlimited operational capacity — no volume caps
  • Unlimited transaction monitoring & alert coverage
  • Unlimited sanctions, PEP & UBO screening of counterparties
  • Unlimited KYC/KYB checks against MLR 2017 customer due diligence
  • Unlimited SAR drafts & evidence packs, delivered to you
  • Six-agent investigation engine, run by our analysts
  • MLRO-grade human oversight & sign-off
  • Quarterly regulatory intelligence report
  • Audit-ready evidence logged on every action
A fraction of one AML/compliance hire (~£55k loaded) — and it comes with the MLRO oversight
Book a Demo
Retainer
Growth
£2,500/month
For Series A/B fintechs scaling their financial-crime compliance operations — rising alert volume, supervisory visits and investor diligence.
  • Everything in Starter, still unlimited…
  • Customer KYC/KYB case management — UBOs, directors & EDD
  • Deeper human oversight on escalated alerts
  • Deeper investigation & SAR preparation allowance
  • Monthly regulatory intelligence
  • Compliance drift & evidence-freshness monitoring
  • Audit preparation mode & sponsor-bank reporting
  • Priority turnaround SLAs
Replaces a 2–3 person compliance pod (£150k+) and the tooling
Book a Demo
Retainer
Enterprise
Coming soon
For BaaS platforms, banks and high-volume regulated products needing dedicated oversight, custom integrations and contractual SLAs.
  • Everything in Growth, still unlimited…
  • Dedicated MLRO / oversight pod
  • Committed investigation & SAR volumes
  • Multi-entity & multi-product management
  • Turnaround & quality SLAs, DPA & UK data residency
  • Custom integrations & governance chains
  • REP-CRIM return data support
Replaces a 6–10 person team (£450k–700k) and the tool stack
Not yet available
02 — Outcome-Based Work Units

Monitoring and screening coverage is uncapped in every retainer. These are the additional outcomes where our analysts and MLROs do bespoke work on your behalf — on request, on top of any retainer. You pay per completed unit, delivered decision-ready, quality-assured and audit-logged. These rates are fixed and predictable across Starter, Growth and Enterprise alike — they don't change because you're on a higher tier, only taper with volume. Custom pricing is reserved for bespoke FCC workflow automation, sponsor-bank reporting integrations, or product-specific compliance requirements — never for the core operation or the rates below.

Completed outcomeYou payvs the market
Customer onboarding completed (KYC)from £6market £10–100 all-in
Business onboarding completed (KYB)from £18complex entity checks
Customer Due Diligence (CDD) completedfrom £8outsourced ~£25–50
Enhanced Due Diligence (EDD) investigationfrom £90market >£100
Sanctions, PEP & UBO screening batch completedfrom £3bundled screening tools charge more
Ongoing sanctions/PEP/UBO re-screening (per counterparty / year)from £3bundled screening & monitoring
AML alert investigated & dispositionedfrom £8industry £20–55 each
Suspicious Activity Report (SAR) preparedfrom £250£800–4,000 all-in
Audit evidence pack deliveredfrom £1,000vs consultancy day-rates
Regulatory intelligence report producedfrom £750often included quarterly
Compliance review completedfrom £3,500Big-4 £1k–2.5k / day
Policy review completedfrom £750vs external counsel
03 — Enterprise Agreement
Bespoke, high-volume

For BaaS platforms, banks and high-volume regulated products running across multiple product lines or entities: a committed annual value with blended per-unit rates, a dedicated MLRO / oversight pod, turnaround & quality SLAs, custom integrations, and volume floors and ceilings. Custom pricing here covers bespoke FCC workflow automation, sponsor-bank reporting integrations and product-specific compliance requirements — not the core operation, which stays on the same fixed, predictable model as every tier. Typically £250k–£750k+ / year — still 40–55% below building the equivalent operation in-house.

Talk to us
How different firms are charged

Early-stage / pre-authorisation fintech

Standing up systems and controls ahead of an FCA application. Unlimited monitoring, screening and SAR drafting, run by us. Starter retainer + a handful of escalated alert investigations.

~£15k / year
~65% less than one analyst + tooling — and MLRO oversight is included

Series A/B fintech, scaling

Authorised, alert volume climbing, investor diligence ahead. Unlimited monitoring & screening coverage, plus 300 escalated alert investigations and 40 SARs prepared each year. Growth retainer + outcome units.

~£43k / year
~60% less than a 3–4 person team + platform

BaaS platform / bank, single product

Unlimited full-book monitoring, dedicated oversight pod, and high-volume alert investigation completed on request. Enterprise agreement + outcome units.

~£220k / year
~55% less than a 6–10 person team + tool stack

BaaS platform / bank, multi-product

A regulated core product plus a second product line or entity under one group. Enterprise agreement, committed annually.

~£380k / year
~45% less than separate compliance builds per product line

There is no software for your team to log into and nothing to meter — every tier includes unlimited transaction monitoring, screening, alert investigation, SAR drafting and evidence packs, delivered by our team. You are never billed per seat, because you are not buying seats: you are billed for access to the operation, and for the work you ask us to complete on your behalf. Outcome-based pricing is fixed and predictable across Starter, Growth and Enterprise — the same per-unit rates apply whichever tier you're on. Custom pricing is reserved for bespoke FCC workflow automation, sponsor-bank reporting integrations, or product-specific compliance requirements — it never applies to the core operation or the standard outcome rates. A “completed” unit means decision-ready, quality-assured and audit-logged — our analysts and VIRGIL prepare, draft and evidence it; your MLRO reviews, signs and files with the NCA. Indicative pricing — final rates are confirmed to your volumes and risk profile.

P(SAR|D) ∝ P(D|SAR)·P(SAR) E[fine] = Σ p¹·F¹ precision = TP / (TP + FP) risk = f(velocity, θ) AML ∩ KYC ∩ POCA
LIVE RESEARCH HUB VOLUME IV · Q1 2026 7EULERIANSTRATEGIES · INSIGHTS
002 / REGULATORY INTELLIGENCE INSIGHTS

Behavioural
science meets
fintech compliance.

Academic research, practitioner analysis, and evidence-based perspectives on how regulatory frameworks, cognitive biases, and AI automation shape compliance decisions — from AML judgment to audit readiness and regulatory risk perception.

24Articles Published
4Research Streams
Q1 2026Latest Edition
Regulatory Behaviour
Stream 01 · 6 articles
Heuristics, biases, and cognitive shortcuts that distort compliance risk perception in fintech teams and MLROs under regulatory pressure.
AML Decision-Making
Stream 02 · 6 articles
Dual-process theory, framing effects, and groupthink in AML alert triage and suspicious activity judgments.
Enforcement & Psychology
Stream 03 · 6 articles
Loss aversion, prospect theory, and the endowment effect applied to FCA enforcement response and regulatory settlement negotiation.
AI & Compliance Futures
Stream 04 · 6 articles
Temporal discounting, automation bias, and trust calibration in AI-assisted compliance and agentic regulatory systems.
FEATURED / MOST RECENT
P(SAR|D) = P(D|SAR)·P(SAR) / P(D)
FeaturedRegulatory BehaviourMar 2026
Mar 2026 · 10 min read

The Availability Heuristic and Systematic Compliance Risk Misjudgment: Implications for AML Detection and Automated Oversight

When the FCA announces a high-profile enforcement action, compliance teams at unaffected fintechs temporarily inflate their own regulatory risk estimates — then revert to systematic under-estimation within months. This paper examines the availability heuristic's role in compliance risk perception and the structural interventions that AI-native compliance platforms can deploy to counteract it.

7EulerianStrategies Research10 MIN1,842 views
SHOWING 8 OF 23 ARTICLES
Interactive Research Tools

The mathematics of
compliance risk.

Four foundational models from decision science and regulatory economics, rendered interactively.

01 · Bayesian AML Updating
P(SAR|D) = P(D|SAR) · P(SAR) / P(D)
Prior P(SAR)0.30
Alert accuracy0.75
False +ve rate0.15
Posterior P(SAR|alert): —
Updating prior SAR probability with new transaction anomaly evidence. Critical for understanding how real-time AML signals should shift an MLRO's prior on expected suspicious activity.
02 · Prospect Theory in Compliance
v(x) = x¹ (gains) · −λ(−x)² (losses)
Loss aversion λ2.25
Gain curve α0.88
Loss aversion ratio: 2.25× gains
Kahneman & Tversky's value function explains why MLROs feel a regulatory fine far more acutely than an equivalent compliance investment saving.
03 · Expected Regulatory Loss
E[L] = Σ¹ p¹ · F¹ · (1 − m¹)
P(AML fine)8%
P(licence action)3%
Automation m35%
Expected annual regulatory loss: —
Computes expected regulatory loss across risk categories with compliance automation mitigation applied.
04 · AML Signal Detection Theory
d′ = (μ_signal − μ_noise) / σ · β = threshold
Sensitivity d′2.0
Threshold β0.0
Hit rate: — · False +ve: —
Models the tradeoff between missed suspicious transactions and false AML alerts in AI-assisted compliance monitoring.
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Use Cases

One market.
Two moments that matter.

We build for Series A–B UK fintechs and nobody else — either you hold an FCA authorisation, or you're preparing the application. The same four capabilities — transaction monitoring, sanctions/PEP/UBO screening, SAR/DAML drafting, audit-evidence packs — configured around which of those two you're living through.

01 · Already FCA-Authorised

EMIs, payment institutions
and Series A–B fintechs.

A 1–3 person compliance team facing rising alert volumes, an MLRO carrying personal liability, and a Series B round where DD teams will test your systems and controls. VIRGIL is configured to your payment flows, your counterparty base and your regulatory stack from day one.

01
Monitoring tuned to payment flow

The six-agent engine is tuned to the velocity, structuring and counterparty patterns typical of EMI and payments flows — not a generic ruleset borrowed from retail banking.

02
Screening, onboarding & KYC/KYB

Payers and payees screened against sanctions and PEP lists on every flagged transaction, with UBO gaps flagged against Companies House — and customer onboarding checked against MLR 2017 reg. 28 from day one.

03
SAR drafts for high-volume queues

FCA-mapped SAR drafts for a two-person compliance team facing alert volumes that would otherwise consume most of the week. Your MLRO reviews and submits — never drafts from scratch.

04
Evidence for s166 and Series B DD

A timestamped audit trail built for an FCA supervisory visit or an investor due-diligence team — ready before either one asks for it.

02 · Applying for FCA Regulation

Firms preparing an
authorisation application.

An FCA authorisation, an EMI or payment institution variation, or an MLR 2017 registration — each turns on demonstrable AML systems and controls, not stated intentions. A case officer tests whether the operation exists and whether it leaves a record. VIRGIL stands that operation up before you apply, so the application describes something already running.

01
A monitoring function that exists

The six-agent engine running against your live transaction data from the day you start preparing — so “we monitor transactions” is a fact with a history behind it, not a commitment in a policy pack.

02
Screening logs a case officer can read

Every counterparty on a flagged transaction screened against sanctions and PEP lists and logged, with UBO gaps flagged against Companies House — the evidence an authorisation or MLR registration decision turns on.

03
Investigated alerts, not empty queues

Alerts worked through to a documented disposition with SAR and DAML drafts where warranted — agent reasoning attached, queued for human review. VIRGIL never files.

04
Application-ready evidence

A live readiness score and timestamped evidence trail mapped to the UK financial crime stack — the systems-and-controls proof an application or variation turns on, ready before the case officer asks.

Somewhere between the two?

Authorised but preparing a variation, or newly approved and still building the operation out — VIRGIL is configured to your transaction data and regulatory stack, not a fixed template. Tell us where you actually sit and we'll show you what that looks like.

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Legal Hub

Policies for
regulated clients.

This hub summarises how 7EulerianStrategies and VIRGIL operate from a legal, privacy, and security perspective. All documents are effective from 1 February 2026.