MSA summary
Master Service Agreement overview
- Standard terms and conditions for AML officer services
- Liability limitations and indemnification clauses
AML Cayman Officer Portfolio
About Martin
FRA
SAR/STR Authority
3–6
Team Members Led
45+
Hours Saved / Month
My name is Martin Popiel. I have been focused on AML/CTF since 2020 and I enjoy creating regulator-grade control environments.
Deloitte-trained CPA, serving as AMLCO, MLRO, DMLRO (Cayman). Experience with BlackRock, CPP Investments, and Brookfield. Responsibilities include AML board reports, SAR/STR escalation to the FRA with DAML consent, REEFS submissions, sanctions & PEP oversight, and training aligned to CIMA Guidance Notes (Feb 2024) and AMLR 2023.
Controls-led approach: independence, maker-checker close-outs, one-page KPIs, and clean audit trails. CPA (Ontario) with multiple Cayman AML/CFT certifications.
Oversight Evidence & Compliance Materials
Concise documents that demonstrate governance, assurance cadence, and regulatory alignment.
v1.0≤1 MB
CIMA §10 Crosswalk excerpt
Control-by-control mapping that shows where each obligation is evidenced in practice.
v1.1≤1 MB
Officer-of-Record One-Pager
Role, scope, guardrails, and appointment conditions—clear enough to circulate internally.
v1.2≤1 MB
Quareterly Assurance Page
KPI tiles summarising SLA adherence, SAR governance, decision timelines, backlog age, and clock-stops.
Legal Pack delivered within 24 hours
Complete legal and compliance documents issued on request.
Master Service Agreement
Statement of Work (SOW)
Outsourcing/Reliance Addendum
Board Appointment & Consent
DPA/NDA
Vendor KYC and Pro-forma Invoice
TPRM Pack (indexed proofs and links)
SOW summary
Statement of Work details
- Quarterly assurance review and reporting cadence
- Board meeting attendance requirements (≤4/year)
Outsourcing/Reliance
Third-party reliance framework
- CIMA outsourcing guidance compliance structure
- Due diligence and ongoing monitoring requirements
DPA/NDA
Data protection and confidentiality
- GDPR and local data protection compliance
- Confidentiality obligations and information handling
Vendor KYC/Payables
Onboarding and payment processes
- Know Your Vendor documentation requirements
- Corporate structure and beneficial ownership
Pro-forma + Fixed Wire SOP
Billing and payment procedures
- Standardized invoice format and timing
- Fixed wire transfer instructions and procedures
TPRM Pack (Index)
Third-party risk management documentation
- Comprehensive risk assessment frameworks
- Vendor categorization and tiering methodology