Regulatory Response and remediation action plan
Our client is a UK branch of a foreign bank. Following the FCA’s intention to provide an update to a previous thematic review carried out in 2010/11 on banks’ anti-money laundering systems and controls in high risk situations, our client was selected as a firm to visit ahead of publication of the FCA’s thematic review on How small banks manage money laundering and sanctions risk (TR14/16).
Prior to the thematic visit from the FCA, Bovill were engaged to provide a review of the AML and Sanctions systems and controls within the London Branch across the following areas:
- Governance and ownership of AML within the entity including MI, reporting and issue escalation processes
- Quality of customer due diligence (CDD) information, including risk assessment and the processes for maintaining up to date client information (e.g. trigger events and periodic reviews)
- Transaction monitoring and reporting processes
- Sanctions screening and PEP identification processes
- Suspicious activity reporting
- Employee training programme
- Document retrieval and retention
- Independent testing of the AML systems and controls.
How Bovill Helped
Following our review and the FCA’s concerns regarding a number of areas that required remedial action, Bovill assisted the firm in responding to the FCA with a strategic response and plan in relation to the findings identified. This included the firm’s proposed approach and timelines for addressing the recommendations highlighted.
The client’s strategic response and remediation action plan was accepted by the regulator alongside the appointment of Bovill, as an appropriately skilled consultant, to provide regulatory advice and assistance in relation to the specific recommendations identified during the review. Bovill have been working with the client over the last year to update AML and Sanctions policies and procedures; performing a branch-wide Financial Crime Risk Assessment to assess the status of relevant controls across the Branch; and providing an interim review against the strategic plan to allow the branch to report on project progress to the FCA.