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.
Our client had a substantial backlog of transaction alerts. They were concerned that these included a number of true positives that therefore indicated suspicious activity and required reporting.
A major global FTSE-100 financial services firm had one month to shape, scope and plan a 60-project programme of work in response to a Section 166 Skilled Persons Report requested by the Financial Conduct Authority (FCA). The firm also had to deliver all 60 projects over a twelve-month period with sub-deliveries due each month.
A UK domiciled crypto exchange with global reach had a regulatory requirement for crypto Money Laundering Reporting Officer (MLRO) support.
