We initially focused in on a randomly selected sample of correspondent banking client files. Our solution included reviews of:
- Customer due diligence.
- Ongoing monitoring reviews.
- Monitoring higher risk situations and the firm’s use of enhanced due diligence.
- Monitoring processes relating to correspondent banking relationships and the monitoring of third party payments.
- Assessing the levels of monitoring of transactions undertaken.
- Assessing the appropriateness of these controls.
We then designed a file review template that could be used to benchmark the bank’s anti-money laundering (AML) controls against regulatory requirements and published guidance, which was then approved by FCA. In addition to submitting the file review findings via this template, we also prepared a summary review of findings.
Our comprehensive review quickly uncovered a number of reoccurring issues. Having widened the review scope to uncover the full scale of the problem, we recommended ways our client could strengthen its AML processes. This included designing a staff training framework for frontline staff to reinforce their important role in AML.