Assessment and remediation of the client monies safeguarding arrangements at a UK EMI.
Payment Services & Card/ Merchant Acquirers
UK Credit Card Provider regulated as a UK EMI and operating fiat-to-digital transfers in conjunction with a UK-registered digital assets firm.
The incoming Head of Compliance at our customer (a UK EMI) identified that Client Monies were not being managed as per regulation and therefore required an immediate remediation.
Lysis Team - Lysis deployed a small, senior team of CASS and Client Monies specialists who had previously held SMF18 (CASS/Client Monies) responsibility in regulated firms.
Investigation - Lysis reviewed the firm's operating model, including a partnership with a digital assets firm offering both fiat and crypto wallet capabilities and conducted an investigation to assess current safeguarding arrangements and regulatory risks. Our finding was that the management of client monies across this service set was not correctly set up, leaving the client open to FCA censure.
Solution Design - Lysis defined the correct model for client money safeguarding including detailed account mapping, set up the necessary client money bank accounts and created a new accounting, reconciliation and reporting framework. Lysis then worked with the client to remediate the current situation to bring it in line with the required model.
The client was then able to demonstrate to the FCA that the issues were resolved and that client monies were correctly safeguarded.
Programme management, target operating model design and global policy development to enable a Fenergo implementation at a major wholesale and investment bank. Lysis Group successfully assisted a global investment bank to design and implement a target operating model in preparation for the implementation of Fenergo.
A UK domiciled crypto exchange with global reach had a regulatory requirement for crypto Money Laundering Reporting Officer (MLRO) support.
A global wholesale bank wished to select and implement a strategic, scalable, flexible client lifecycle management application that would be able to support the customer assessment requirements of its KYC and MiFID programmes as part of its Compliance framework.
