Skilled person review of branch of European investment bank
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.
- 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
- 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