Ouch… Not Again

Is it not amazing that a person convicted of a white-collar crime, Fraud, Market Manipulation, can make one error that sends them to prison or alters their life forever? Yet the most notable Banks around the world can be complicit in much more heinous crimes, and simply get fined (which usually is not significant enough to adversely affect them) and carry on ‘business as usual’.

Leading up to 2022, we saw several fines dealt out by the Financial Conduct Authority (FCA). Of which, one of the most notable was NatWest, who were fined approximately £264 million following convictions of three offences in relation to not complying with Money Laundering regulations[1]. Frequent deficiencies, such as this, may warrant the regulator to conduct a Skilled Person review under S166 of the Financial Services and Markets Act (FSMA). If this happens, the FCA will commission a report or ask the firm in question to nominate a Skilled Person to undertake the work. K

ey aspects of a successful review include a firm’s willingness to be open and transparent to the regulator. However, if you have never been through such a review before, how do you know what to expect?

This is where Lysis can help.
We have a range of experts and significant experience in assisting clients with complex and contentious regulatory issues. Our section 166 team is organised into internal practice groups and our key point of difference is the integration of experienced financial regulation specialists, with senior compliance advisors specialising in operational governance, risk, and compliance; combining sound technical and industry consultancy experience. ​

We can also provide guidance on what you might expect during this process and how to prepare.

Key considerations would include:
Current company policies and procedures, such as those relating to Customer Due Diligence (CDD), Suspicious Activity Reporting (SAR) procedures and Transaction Monitoring;
Roles and responsibilities of senior management, such as those of the Money Laundering Reporting Officer (MLRO) and their delegates;
Governance arrangements, including escalation routes;
Colleague training and awareness;
Customer screening (PEPs and Sanctions), including rules management;
Firm wide threat and risk assessments; Monitoring and oversight arrangements;
and Culture and tone from the top.

For further information please contact Gabriel Cozma, Head of Lysis Financial at

Lauren Parmenter Consultant [1]

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