A U.K. based broker dealer required assistance with the management of their Financial Conduct Authority (FCA) issued Section 166 remediation notice.
Corporate, Wholesale and Investment Bank
Governance & Compliance Framework/ Section 166/ SMCR
A U.K. based broker dealer.
The project included programme governance, RAID, and tracking tools to ensure accurate and timely delivery, working with executive and senior management to initiate the programme and projects, to build the team required and to respond to initial regulator challenges on the programme and project set-up. Lysis also managed the entire global programme, spanning the Governance, Risk, Compliance, Operations, and IT functions, reporting to a board-level steering committee. Lysis took responsibility for programme management, planning, tracking, and reporting, including programme risks, issues, dependencies, and the budget.
Lysis assisted the client successfully with their S166 remediation requirements as per the FCA specifications and further proposed changes to the global governance structures, boards, committees, and legal entity governance which included:
- Senior management remuneration.
- The role and activities of the audit committee.
- Group policies, delegated authorities, and escalation arrangements.
- Board-level management Information.
- The role and effectiveness of NED's.
- Governance, structure, and operation of the compliance function.
- Global and regional compliance policies.
- Arrangements for transaction reporting and market abuse detection.
- Governance, structure, and operation of the risk management function.
- Risk management policies including ICAAP.
- The design and implementation of strategic planning arrangements.
Our client was setting up a new online gaming licensing authority and sought a partner to on-board licensees and to manage the on-going governance and compliance operation.
The incoming Head of Compliance at our customer identified that Client Monies were not being managed as per regulation and this therefore required an immediate remediation.
Our client had a substantial backlog of transaction alerts. They were concerned that these included a number of true positives that therefore indicated suspicious activity and required reporting.
