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.
Investment and Asset Management
Client On-Boarding and AML Managed Services
The client needed a seasoned and specialised financial crime (FC) compliance firm to conduct Anti-Money Laundering (AML) assessments on their entities which the client lends money to.
Lysis assists the client with this requirement under the Irish legislation which is the Criminal Justice (Money Laundering and Terrorist Financing) Act of 2010 because the client is incorporated and regulated in Ireland and Ireland forms part of the European Union (EU). The ongoing service offering includes end-to-end Know Your Customer (KYC) operations which is managed by Lysis' secure Cape Town-based operating centre. The set of entities that the client does business with is complex because some of the client's borrowers are unregulated entities which are based in the US with affiliations to high-risk jurisdictions and others are New York Stock Exchange (NYSE) listed entities. As with many listed entities, this client also conducts business with Politically Exposed People (PEP's) who are often associated with listed business entities. However, being identified as a PEP does not necessarily mean that they are involved with illicit activities but, as part of the AML framework requirements, conducting enhanced due diligence is required for high-risk entities.
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.
Our client had a requirement to review and update its AML Framework to take account of the Fifth Money Laundering Directive and also some changes in its business model.
Our client had a large backlog of increasingly old transaction alerts that potential indicated suspicious activity and required reporting.
