Jul 31 / Evdokia Pitsillidou

A Complete Client Onboarding Procedure as per AML & MiFID in 2026

about the author

Evdokia Pitsillidou

Global Chief Risk & Compliance Officer at SALVUS Funds

Evdokia, a partner at SALVUS Funds, is actively advising and working on all matters related to licensing, regulatory compliance, and internal audit for investment firms, funds, Electronic Money Institutions (EMI) & Crypto-Asset Services Providers (CASP).

  • Member of the Global Institute of Internal Auditors (IIA)
  • Member of the Cyprus Investment Funds Association (CIFA)
  • Certified Actuarial Analyst (CAA)
  • CySEC Advanced Certified Person
  • CySEC certified Anti-Money Laundering Compliance Officer (AMLCO)
Client onboarding is where risk control begins. For regulated entities, onboarding must do more than collect information. It must identify risk, assess suitability, support compliance, and set the foundation for effective ongoing monitoring. 

In this blog post, Evdokia Pitsillidou, Global Chief Risk & Compliance Officer at SALVUS Funds, shares practical insights on client onboarding, the Risk-Based Approach, and the key AML and MiFID considerations firms need to apply in practice. 

“A Complete Client Onboarding Procedure as per AML & MiFID in 2026” is now available on the IforPE platform. 

What is the Client Onboarding Procedure? 

Client onboarding is the structured process firms follow before accepting a new client. It helps them understand who the client is, assess the risks involved, and decide whether the relationship aligns with their regulatory obligations and risk appetite. 

A complete onboarding procedure usually includes: 

  • Client acceptance: deciding whether the relationship fits the firm’s risk appetite 
  • Client identification and KYC: verifying identity, ownership, and due diligence information
  • Screening: checking clients and related parties against sanctions, PEPs, adverse media, and other risk lists
  • Client economic profile: understanding source of funds, source of wealth, financial background, and expected activity
  • Risk assessment and AML risk scoring: assigning the right level of controls based on risk
  • Appropriateness, suitability, and target market assessment: ensuring products and services match the client’s profile and needs
  • Remote onboarding controls: confirming digital tools are reliable, compliant, and monitored
  • Ongoing monitoring and record keeping: keeping the relationship aligned with regulatory obligations and the firm’s risk appetite


When done properly, onboarding helps firms reduce risk, meet AML and MiFID requirements, and build stronger, more transparent client relationships. 

Risk-Based Approach 

The Risk-Based Approach helps firms focus their controls where the risks are highest. Instead of treating every client the same, firms assess the client’s profile, jurisdictional exposure, ownership structure, products or services used, delivery channel, expected activity, and any red flags that may require closer attention. 

In practice, this means asking the right questions from the start, documenting the risk assessment, and applying controls that match the level of risk. Higher-risk clients, complex structures, or links to high-risk jurisdictions may require enhanced due diligence and ongoing monitoring to ensure the relationship remains within the firm’s risk appetite. 

What is the “A Complete Client Onboarding Procedure as per AML & MiFID in 2026” course and what does it include?

 The course is delivered by Evdokia Pitsillidou, Global Chief Risk & Compliance Officer and Partner at SALVUS Funds. It is designed for professionals involved in AML, compliance, onboarding, risk management, operations, internal audit, and regulatory monitoring, especially within CIFs, CASPs, Payment Institutions, funds, EMIs, and other regulated entities.

Professionals undertaking this course will acquire the skills and competencies necessary for enhancing their firm's AML/CFT requirements and regulatory compliance. After this course, they can ultimately ensure comprehension of key information regarding the client onboarding procedure according to AML and MiFID regulations.

The syllabus of the course includes:

  • Money Laundering (ML) & Terrorist Financing (TF)

- What is Money Laundering (ML)?
- The stages of Money Laundering (ML), and examples
- The methods of Money Laundering (ML)
- What is Terrorist Financing (TF)?
- Similarities and Differences between Money Laundering (ML) and Terrorist Financing (TF)
- Money Laundering Offences

  • The AML Regulatory Framework 
- Supervisory and Law Enforcement Authorities
- Powers of CySEC
- AML Regulatory Framework
- MOKAS' powers

  • Assessing and Managing Risks – Risk Based Approach (RBA) 
- Risk-Based Approach (RBA)
- Primary risk factors and associated risks
- Keeping risk assessments up to date
- Business-wide risk assessments
- Individual risk assessments
- Business-wide & Individual risk assessments
- Assessing and Managing ML&TF risks by Sector

  • Know Your Customer (KYC) and Customer Due Diligence (CDD) 
- Customer Due Diligence
- Identity Identification
- Simplified Customer Due Diligence (SDD)
- Enhanced Customer Due Diligence (EDD)
- Financial inclusion and De-risking
- Documentation Reliance
- Reliance on third parties

  • Client Appropriateness and Target Market 
- Client Suitability and Appropriateness
- Manufacturer & Target Market Identification
- Distributor & Target Market Identification
- Negative Target Market Identification

  • Client Onboarding Process 
- Client Acceptance Policy
- Customer Identification
- Screening (PEPS and Sanctions)
- Customer Economic Profile
- Appropriateness Test – Good Practices
- Use of Remote Onboarding Solutions

  • AML Risk Scoring
- Primary risk factors and associated risks
 - Weighting risk factors
- Practical Examples - MOKAS Report ’2024

  • AML/CFT Red Flags & Typologies

- EBA’s 5th Opinion on ML/TF risks
- FATF Targeted Report on Stablecoins
- MOKAS Strategic Report 2025

  • Ongoing Monitoring and Record Keeping

- Ongoing Monitoring
- Record Keeping
- Overview of the Onboarding Process

The course is delivered through online video recordings and downloadable PDF study material, allowing professionals to learn whenever and wherever it suits them best. Participants can progress at their own pace, revisit topics as needed, and reinforce their knowledge through accessible and structured learning resources.  

Upon successful completion, participants receive a certificate awarding 5 CPD hours, recognised by CySEC, the Central Bank of Cyprus, and other professional supervisory bodies. The course contributes towards the annual CPD requirements of CySEC Advanced, Basic and AML Certification holders, as well as professionals registered with ICPAC and the Cyprus Bar Association.
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If you have any questions about Evdokia's course or any other questions related to your training requirements, please contact us; we would love to help.
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