A major European-domiciled Cryptoasset Exchange with global reach required a gap analysis to identify all deficiencies in their Customer Risk Rating Model and a roadmap for improving it.
Crypto/ Digital Assets
Financial Crime Framework Review and Enhancement
A major European-domiciled Cryptoasset Exchange with global reach.
The client had a requirement to design a new AML Customer Risk Rating Methodology (RRM) to facilitate the risk assessment of its customers.
Lysis conducted a gap analysis to identify all the deficiencies of the current risk rating methodology. A roadmap was subsequently designed which laid out a plan for implementing the suggested enhancements. The process included an in-depth analysis to demonstrate the various cross-jurisdictional compliance requirements, including the identification and weighting of those risk factors specific to their business and industry. The next step consisted of the testing of a new Customer Risk Rating Methodology on a sample of the client's customers to determine the impact on their Customer AML Risk Rating and thereby ensuring that the results aligned with expectations in terms of the Risk-based Approach. Lastly, Lysis conducted User Acceptance Testing (UAT) of the new AML Customer Risk Rating Methodology.
Our client was looking at options for the location of new Level 2 teams to support retail customers with affordability and suitability issues.
The client is incorporated in Ireland as an Irish Collective Asset-management Vehicle (ICAV). The client is an American investment fund which specialises in lending large amounts of money to various entities ranging from listed entities to unregulated entities based in the USA.
The incoming Head of Compliance at our customer identified that Client Monies were not being managed as per regulation and this therefore required an immediate remediation.
