Consulting & Advisory

FC Framework, Uplifted SAR reporting, engaged with the FCA

Following a review from the Financial Conduct Authority (FCA) in 2021, and a subsequent letter from the regulator, the client had to address a number of gaps that were identified by the regulator.

The Client

A UK-based alternative banking and payment platform that offers innovative pay-tech solutions to global clients.

The Challenge

Lysis was asked to assist the client in managing the relationship with the regulator and to help with the response to the regulator. This also included assisting the client to deliver the requirements that was specified by the regulator including the compilation of a roadmap that specified all deliverables over a period of time and several improvements to their existing financial crime framework.

The Solution

Lysis worked closely with the client in preparing the letter of response to the regulator highlighting priorities and commitments linked to specific timelines which was detailed in a roadmap. Lysis also delivered a number of activities including the high-level design of a robust financial crime framework, rewrote their policies and procedures, uplifted the client’s risk assessment and their financial crime governance structure, improved their Know Your Customer (KYC) processes and uplifted the Suspicious Activity Reporting (SAR) procedures. Last but certainly not least, Lysis also assisted with the drafting of the client’s MLRO reports.


Lysis provided the client with a comprehensive understanding of the risks within their business and offered practical advice and assistance on how to mitigate these risks by having proportionate controls in place.Lysis further advised the client to continue their proactive engagement with the FCA and to also ensure that all the identified gaps are addressed to demonstrate their commitment to meet all the FCA requirements within a specified timeframe. Lysis also established a solid relationship with the client where they could reach out for assistance with any future financial crime compliance requirements that might be stipulated by the FCA.

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