Case study: Past business review
Quickly scaling up to deliver largescale PBR
AML defences reinforced with review
A UK-based retail bank had attracted the attention of the FCA because of the number of high-risk clients on its books. An internal review had also shown that client files in certain business units were missing know your customer (KYC) due diligence information. Concerned about potential reputational damage, our client knew it needed an independent third party to review its files and assess the risk.
We initially focused in on a randomly selected sample of correspondent banking client files. Our solution included reviews of:
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.
By partnering with an independent third party, our client could be sure that its new controls were robust and avoided any potential reputational damage associated with not taking AML responsibilities seriously.
“Our comprehensive review quickly uncovered a number of reoccurring issues
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