Operations & Resourcing

KYC Remediation: Section 199 order

A major wholesale and investment bank with global reach was placed under a Section 166 order regarding their KYC and AML controls.

The Client

A major wholesale and investment bank with global reach

The Challenge

Following an ARROW visit from the regulator the firm was put under a Section 166 order due to concerns around their Know Your Customer (KYC) and anti-money laundering (AML) controls.The regulator found deficiencies regarding the firm’s identification and risk rating of Politically Exposed Persons (PEP’s) along with the inability to remediate client files in line with regulatory expectations.

The Solution

Lysis worked with the Money Laundering Reporting Officer (MLRO) and global head of operations to provide the following services:• Mobilised 50 KYC Subject Matter Experts (SME’s) and embedded an operational and management structure to work according to the client’s demands.• Placed a team of KYC SME’s and an Operations Manager in Hong Kong to ensure local business requirements were met.• Screened 10,000 clients, with 50,000 associated individuals, within three months in order to identify PEP’s.• Remediated 5500 clients with a global reach across all client risk ratings.


• Successfully worked with the client to pass the regulatory Section 166 review.• Identified, risk rated and produced profile reports for 5000 PEP’s including 500 individuals classified as high risk.• Completed 5500 KYC reviews in line with regulatory deadlines including 1000 high risk clients.• Embedded a periodic review process to ensure that the firm can deal with remediation requirements going forward.• Provided skilled resources to the business as usual (BAU) client on-boarding team to ensure business demands were met on a daily basis.

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