Enhancement of AML Governance Framework and KYC Remediation

A major wholesale and retail bank with global reach had deficiencies it is AML governance framework and consequently with its KYC operations.

Division
Consulting & Advisory
Industry

Corporate, Wholesale and Investment Banking

Service-line

Financial Crime Framework Review and Enhancement

The Client

The London operations of a major wholesale and retail bank with global reach.

The Challenge

The firm was under pressure from the UK FCA to plan and execute a programme of work to fix the deficiencies.

The Solution

Lysis worked with board members and senior management to review the firm's processes and controls from an AML perspective.

 

We then developed new policies and procedures covering client on-boarding/off-boarding, KYC, sanctions, PEP screening and transaction monitoring across Trade Finance, Treasury Services, FX and Money Markets and Securities Trading.  A programme of training and embedding ensure that the new policies and procedures were implemented successfully.

 

Lysis advised the Board on the establishment and operation of a Financial Crime Escalation Committee to provide governance around AML and financial crime at a board and senior management level.

 

Lysis successfully implemented the incoming FATCA regulations for the firm, including policies, procedures and training.

 

Lysis provided a team to remediate all AML/KYC files to the new policies and procedures.

 

Finally we worked with the bank to re-engineer the KYC department as well as providing on-going Know Your Customer (KYC) and quality assurance (QA) support.

Results
The outcome consisted of a fully documented AML and KYC governance framework and enhanced policies and procedures that were designed to suit the needs of the business as well as to ensure on-going compliance to the U.K. regulations. Also, on-boarding efficiencies were maximised by applying the agreed procedures. Lysis left the client with an efficient and dynamic KYC department that were able to meet the demands of the business.
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