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).
Payment Services & Card/ Merchant Acquirers
A newly FCA regulated EMI in the UK
The EMI had just been authorised by the FCA and now needed to ensure its Compliance Monitoring Framework was fully embedded and operational.
Lysis had assisted the firm to design and document its Compliance Monitoring Framework during the authorisation process. 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) and the relevant industry standards and internal policies.
Lysis then developed a post-authorisation roll-out plan to ensure that the framework was operational across the firm:
• We trained relevant staff in their obligations under the plan. Staff obligations included ensuring the effective of real-time and periodic checks to detect non-compliance issues as they arise. The scope included areas like anti-money laundering (AML), data protection (e.g. GDPR), financial reporting, licensing and employee conduct.
• We supported our client to set up the relevant governance and reporting for compliance monitoring.
• We helped the firm to implement appropriate systems and manual processes and provided interim staff to resource the work while our client recruited.
We then conducted an initial review of how effectively the controls and monitoring were operating.
Subsequently we provided some of the monitoring services via a managed service arrangement, including client on-boarding and refresh and AML transaction monitoring and screening.
We also provided an MLRO support service.
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One of our client's banks has flagged areas of our client's Ant-Money Laundering (AML) Governance and Compliance operation as a potential cause for concern. Our client asked Lysis to perform an independent review for them to establish if anything was genuinely wrong.
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