Skilled person review of branch of European investment bank

Client Summary

Following a recent FCA visit, the London Branch of a European Investment bank was instructed to appoint a skilled person to assess their financial crime systems and controls. The scope of the review was AML, Sanctions and Anti-Bribery and Corruption across all business lines in the London Branch. The review was due to complete in short timescales over the peak summer holiday period.

Project Objectives

  • The FCA were looking for a review and recommendations report into the Bank’s financial crime systems and controls. The timescales were challenging for the size of the firm involved.
  • The review covered: governance, client risk rating, CDD / EDD, periodic and event driven reviews, business risk assessment, sanctions, transaction monitoring, suspicious activity reporting, client exits, trade finance, anti-bribery and corruption and the firms remediation programme.

How Bovill Helped

  • Bovill quickly mobilised a project team comprising the skilled person, approximately 13 financial crime subject matter specialists and project management support
  • We structured the programme around 12 key workstreams with close central engagement management with the Bank
  • We used a secure data room to facilitate the safe and quick transfer of confidential information
  • As well as the effectiveness of systems and controls, we assessed the competence of senior business and compliance personnel
  • We worked closely with the bank to support their understanding of our requests and to enable them to provide the right information to us in a timely manner
  • Emerging issues were raised in a timely manner whether they were relating to progress (daily calls) or findings (bilateral) to ensure the firm were able to respond appropriately and in a timely manner
  • Practical recommendations were provided, supporting the firm in addressing risks and not merely delivering tactical fixes to their controls

Results

  • Our team identified numerous issues which the bank were not aware of, assisting them in enhancing their control environment
  • Clear, thorough and well evidenced observations were provided, ranked in terms of their materiality, to enable the firm to quickly and appropriately set in place remedial actions
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