Lysis deployed a team of AML and regulatory specialists to carry-out a review of the firm's governance framework relating to AML. They also reviewed all policies and procedures relating to AML, ABC and sanctions and reviewed and tested all operational processes and systems relating to AML including KYC and transaction monitoring. In addition, Lysis interviewed all key staff from executive management to operational staff in order to establish the level of understanding and cultural awareness around AML and compliance. They further tested the Three Lines of Defence model in the firm to review its effectiveness.