Financial crime prevention continues to receive considerable FCA attention. While all regulated sectors are subject to scrutiny, areas including wealth and investment managers, electronic money institutions and those dealing with cryptocurrency are seeing increased activity and expectations set against them, including requirements to submit the financial crime data return (REP-CRIM).
With continued focus and the regulators increased willingness to deploy regulatory tools, many firms are increasingly nervous about the likelihood of regulatory engagements, what these will entail and the potential consequences, whether they be operational, economic or reputational.
Financial crime regulation - a risk based approach
A risk-based approach sits at the heart of the FCA’s financial crime supervisory strategy, with the regulator being increasingly vocal in their aspirations to use a wide variety of data to ensure a risk-sensitive and targeted supervisory approach across sectors.
There are several different visit types and engagements firms can be exposed to, disrupting and challenging organisations who must balance delivering service to customers, meeting a variety of compliance obligations and managing engagements from the regulator when they occur.
Whether your firm is taking a proactive approach to manage risk or are responding to an FCA engagement, our experts can support you every step of the way, ensuring you’re able to manage risk, meet obligations and respond to requests from the regulator in a timely and effective manner.
Our team have extensive financial crime experience, including within the FCA’s financial crime specialist supervision team, having undertaken SAMLP, PAMLP, risk assurance and thematic visits.
How we support
S.166 reviews
We've supported many Skilled Person reviews over the years and have also undertaken significant Monitorship activity on behalf of the Department of Justice in the US. We know what regulators are focused upon and will ensure we are transparent, fair and proportionate when conducting a skilled person review.
We have performed a wide variety of financial crime skilled person reviews across large international banks, domestic challenger banks, overseas head quartered investment firms and EMI authorised institutions.
S.166 firm side support
Where we are not the appointed skilled person, we can support you and your firm through the entire review and provide firm side support.
We support you from start to finish, ensuring you are fully prepared and engaging with the skilled person review in the right way. We’ll be at your side throughout, supporting you with the preparation of information and people ahead of a visit, and highlighting likely observations throughout.
After the visit we can help you make sense of it all, advising of suitable communications with the relevant regulatory bodies and design appropriate remedial action plans that give regulators comfort that the issues are being addressed, without setting you up to fail by committing to unachievable goals.
Assurance and independent reviews (AML health checks)
Whether you have self-identified, or as the result of an audit, regulatory visit or even a request from your banking partner we can provide you an independent view of your fraud and financial crime framework. Our understanding of what peers are doing accelerates your progress and ensures you’re not “behind the pack”.
Drawing on our years of experience, we’ve worked with institutions of all shapes and sizes across the world, always delivering a tailored approach, fit for who you are and what you need.
Fraud and financial crime risk assessments
We have supported firms across a variety of regulated sectors in developing tailored and actionable risk assessments. Our tailored process defines your methodology, and performs the risk assessment, before developing risk-based action plans. We maintain an extensive risk library and have extensive experience in understanding mapping and assessing both inherent risks applicable to your business as well as your control environment to calculate the final residual risk.
By leveraging real-time risk assessment technology supported by our experts, we can also calculate your fraud & financial crime risk heat maps as often as you require; whether that be monthly, quarterly, or annually.
Training – AML/MLRO and mock interviews
We design and deliver high-impact training, from an initial needs analysis, content development, delivery and training assessments. We can also deliver product specific training such as trade finance, factoring and leasing
We also provide mock FCA / regulatory interviews to support you or your teams with both S.166 reviews or interviews with the regulator.
Horizon scanning
Bringing together a powerful, yet simple regulatory horizon scanning platform and our expert knowledge, we can provide a horizon scanning capability that is simple to engage with, collaborative by nature and backed up with tracking and auditing capability to demonstrate and report to stakeholders and regulators alike.
High value dealers
We have also supported many businesses in non-regulated sectors, providing an independent AML/CTF review when requested by their bank, ensuring it is not simply a benchmark against regulatory requirements but bespoke to the fraud and financial crime risks your business faces.
Let's talk
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