Situations
The moments that usually start a conversation.
People rarely wake up wanting a compliance program. They write because someone outside the company asked a concrete question. These are the situations the practice is built for. If yours is different, say so in the enquiry. We would rather decline a poor fit than stretch a service until it misdescribes the work.
01
A bank or partner asks for policies
A relationship manager, a marketplace, or an investor sends a questionnaire. It asks for your onboarding steps, your record retention, your vendor checks, and the name of the person responsible. The deadline is shorter than the questionnaire looks.
What helps is a pack that matches the questions and does not claim controls you have not started. A gap assessment is usually the right first service. If the gaps are already understood, policy drafting can follow under the same proposal or a second one. We will not write “fully compliant” on a cover page.
02
You start serving people in the European Union
A Moldovan company takes on customers, subscribers, or business contacts in the EU. Contracts start to mention data protection. A customer asks where their information is stored and who else sees it. The team has a spreadsheet and a habit, not an inventory.
Data protection readiness produces the inventory, a retention schedule, a draft notice, and a way to handle requests. It does not replace a lawyer’s view of which law applies, and it does not appoint us as your representative in the EU. If customer checks are also in the questionnaire, the AML routine is a separate line in the proposal so the two topics are not blurred.
03
A supplier will touch personal data or client money
You are about to sign with a payroll firm, a cloud tool, a logistics partner, or a white-label provider. Someone asks, late, whether the contract says anything about sub-processors, breach notice, or how you leave. Procurement has a price comparison and no review record.
Vendor diligence gives you tiers, questions, and a one-page record of the decision. Your lawyer still negotiates the clauses. We do not score the supplier as “safe”. We record what you asked, what they answered, and what remains open.
04
A new product does not fit the old procedure
The company adds a channel: online sign-up, a reseller, a higher-value client, or a service that holds funds for a few days. The old procedure assumed a paper file and a director who knew every customer. Staff are improvising, and the improvisation is not written down.
This is program design or a focused redraft, depending on whether the governance exists. We rewrite the path for the new channel and leave the untouched products alone. A program that tries to describe every future idea becomes fiction.
05
The first hire who will handle client records
Until now the founder opened every file. A new colleague will see personal data, payment details, or customer identities. There is no note of what they may copy, where they save it, or who they call if something looks wrong.
A short procedure and a briefing are often enough. We do not write an employee handbook or an employment contract. Those belong to counsel. We write the control the new person must actually perform in the first month, and the record that shows they did.
06
A buyer or investor asks how the company is controlled
Due diligence questions arrive in a spreadsheet. They want owners of policies, the last review date, and any open findings. Answering from memory, the night before, produces contradictions.
If the documents do not exist, say so and commission a gap assessment that a buyer can read without blushing. A frank gap note is more credible than a policy dated last week that nobody has used. We will not dress a new file as a long-standing program.
If this is you
Describe the request you received, not the program you wish you had.
Paste the question you were asked, name the business line, and tell us the date you are working toward. We will say which service fits and whether the date is realistic. The fee lives in the written offer, after that conversation.