A listed UK-Based subprime lender offering lower value short term loans needed to enhance, redesign, and implement a new FC framework. Lysis provided the client with a understanding of risks, practical advice on risk mitigation, & robust policies.
Retail & SME Banking
Financial Crime Framework Review and Enhancement
A listed UK-based subprime lender that offers lower value short-term loans, either unsecured or with a guarantor, to individuals who are unable to secure or qualify for a loan from the mainstream financial firms mainly due to their financial circumstances and who may also be considered vulnerable customers.
Due to the specific industry that the client operated in, they had a strong focus on the prevention of fraud but had little expertise about how to mitigate the risks associated with their business environment. Through workshops, Lysis was able to impress upon the client the risks faced by the business and advise on implementing proportionate controls which would operate under a mix of manual and automated functions to be effective in mitigating the FC inherent risks. Lysis further guided the client on the requirements for a robust FC governance and operational structure. Lysis successfully redrafted some of their existing policies and wrote additional policies, in readiness for the launch of their new product, that met the specific financial crime requirements as determined by the FCA. This included a comprehensive financial crime policy, a risk rating policy, Financial Crime Risk Assessment, Client Risk Rating, Risk Assessment Statement, Risk Assessment Methodology as well as the TM and on-boarding procedures. Lysis conducted a number of workshops to include the business, the FC operations and FC specialist team that specifically focussed on the requirements to launch their new product offering, how to manage the process going forward whilst remaining compliant. The workshops increased the level of knowledge regarding financial crime across staff from the 1st and the 2nd line of defence of the organisation. Lysis further engaged with their third-party providers to gain a clear understanding of the services offered and to ensure their functionality for onboarding, screening, transaction monitoring, management of alerts etc., were aligned with the client's policies and procedures and could be managed in a highly effective and efficient manner.
Assessment and remediation of the client monies safeguarding arrangements at a UK EMI.
A major European-domiciled Cryptoasset Exchange with global reach required a gap analysis to identify all deficiencies in their Customer Risk Rating Model and a roadmap for improving it.
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.
