Lysis designed and implemented a compliance monitoring framework for a UK-regulated EMI. The aim of the framework was to ensure ongoing compliance with the Electronic Money Regulations 2011 (EMRs), including with the Money Laundering Regulations 2017 (MLRs).
Payment Services & Card/ Merchant Acquirers
A newly FCA regulated EMI in the UK
The EMI had just been authorised by the FCA and now needed to ensure its Compliance Monitoring Framework was fully embedded and operational.
Lysis had assisted the firm to design and document its Compliance Monitoring Framework during the authorisation process. The aim of the framework was to ensure ongoing compliance with the Electronic Money Regulations 2011 (EMRs), including with the Money Laundering Regulations 2017 (MLRs) and the relevant industry standards and internal policies.
Lysis then developed a post-authorisation roll-out plan to ensure that the framework was operational across the firm:
• We trained relevant staff in their obligations under the plan. Staff obligations included ensuring the effective of real-time and periodic checks to detect non-compliance issues as they arise. The scope included areas like anti-money laundering (AML), data protection (e.g. GDPR), financial reporting, licensing and employee conduct.
• We supported our client to set up the relevant governance and reporting for compliance monitoring.
• We helped the firm to implement appropriate systems and manual processes and provided interim staff to resource the work while our client recruited.
We then conducted an initial review of how effectively the controls and monitoring were operating.
Subsequently we provided some of the monitoring services via a managed service arrangement, including client on-boarding and refresh and AML transaction monitoring and screening.
We also provided an MLRO support service.
Our client had a large backlog of increasingly old transaction alerts that potential indicated suspicious activity and required reporting.
Our client had implemented a new transaction monitoring system and wished to ensure that the previous two years' transactions had been monitored effectively.
A crypto asset custodian based in the U.K. with global reach approached Lysis with the request to assist them with the process to obtain registration from the FCA which would enable them to operate in the UK market as a crypto asset business. Due to the holding company’s strong global footprint, part of the FCA requirements for registration included the need for a UK based money laundering reporting officer (MLRO).
