A significant UK and US corporate bank with questions around the quality of the firm’s AML capabilities and customer files
Corporate, Wholesale and Investment Banking
KYC Remediation
A significant UK and US corporate bank
The bank had grown rapidly and an audit in late 2020 raised questions about the quality of the firm’s AML capabilities and customer files.
Lysis worked with the bank’s AML compliance and AML operations team to provide the following services:
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).
Although the client is based in the US, they have European subsidiaries which include the UK and therefore required Financial Conduct Authority (FCA) registration. In order to obtain registration as a crypto asset firm in the U.K. they had to comply with specific FCA requirements.
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).
