A UK-crypto asset subsidiary of a Nasdaq-listed firm in the U.S. has a requirement to review their anti-money laundering (AML) policy framework and idetify possible gaps in line with FCA requirements.
Crypto & Digital Assets
UK-crypto asset subsidiary of a Nasdaq-listed firm in the United States.
This called for a health check which consists of a high-level review of the design of a firm’s FC framework to identify problem areas.
Lysis reviewed the client’s policy framework and made recommendations for uplifting the policies based on identified gaps. From a content perspective, this included a review to determine if the policies are documented and aligned with the firm’s standards across all the business sectors.Testing of the controls can only take place once all the policy recommendations were embedded into the client’s policy framework. Ineffective policies by design will result in ineffective implementation and this will impact the testing of controls negatively.
Lysis provided the client with a detailed report that contained the findings of the review. The report helped the firm to conduct a gap analysis against their current approach to AML and current regulatory requirements which allowed the firm to gain a detailed and independent understanding of its AML governance framework.
A new to market crypto asset business domiciled in Ireland received a regulatory requirement from the Central Bank of Ireland to design and embed a financial crime, AML/CTF, governance framework.
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).
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).
