Because of our deep understanding of FCA standards, we knew our review needed to consider both the initial customer due diligence undertaken and also the process for monitoring the ongoing client relationship and transactions. We took a phased approach:
- Phase one –we started by reviewing past cases to find out whether our client was collecting sufficient information. Did our client fully understand their customer intentions? Had it properly verified identities, including identifying the beneficial owner(s)? Does it enter into, or continue, relationships even if it can’t conduct customer due diligence?
- Phase two –secondly, we reviewed the customer due diligence procedures and processes, testing them against what we were seeing in practice. In particular, we wanted to know whether the procedures were flexible enough to cope with customers who needed enhanced due diligence, such as PEP’s or those who can’t provide the most common forms of ID.
We left no stone unturned. And thanks to the depth of our review, our client had a complete view of their customer due diligence processes, inherent weaknesses, and the outcomes they resulted in. We then suggested a number of improvements they could make to ensure their processes could stand up to regulatory scrutiny and reduce risk.