A U.K. based broker dealer required assistance with the management of their Financial Conduct Authority (FCA) issued Section 166 remediation notice.
Corporate, Wholesale and Investment Banking
Governance & Compliance Framework/ Section 166/ SMCR
A U.K. based broker dealer.
The project included programme governance, RAID, and tracking tools to ensure accurate and timely delivery, working with executive and senior management to initiate the programme and projects, to build the team required and to respond to initial regulator challenges on the programme and project set-up. Lysis also managed the entire global programme, spanning the Governance, Risk, Compliance, Operations, and IT functions, reporting to a board-level steering committee. Lysis took responsibility for programme management, planning, tracking, and reporting, including programme risks, issues, dependencies, and the budget.
Lysis assisted the client successfully with their S166 remediation requirements as per the FCA specifications and further proposed changes to the global governance structures, boards, committees, and legal entity governance which included:
- Senior management remuneration.
- The role and activities of the board and sub committees, and compliance with senior manager regime (SMCR).
- Group policies, delegated authorities, and escalation arrangements.
- Board-level management Information.
- The role and effectiveness of NEDs.
- Governance, structure, and operation of the compliance function.
- Global and regional compliance policies.
- Arrangements for transaction reporting and market abuse detection.
- Governance, structure, and operation of the risk management function.
- Risk management policies including ICAAP.
- The design and implementation of strategic planning arrangements.
A major Egyptian bank with UK operations had a requirement to identify possible AML and CTF gaps and suggested improvements.
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.
Our client had acquired a business from a competitor and had c.50-60 Payment Programme Managers and their programmes to on-board. They asked Lysis to supply a team of experts to do this work.
