A major European wholesale and investment bank with global reach asked for help meeting customer classification requirements.
Corporate, Wholesale and Investment Banking
Classification/ MiFID/ MICA
The firm operated in all the major global financial markets and was therefore required to classify customer sophistication according to each local classification regime. Equivalence between regimes was difficult to establish making it necessary to classify customers multiple times if they did business with the bank in multiple locations. The firm also had many cross-border trading activities with U.S. customers which required adherence to the U.S. 15A6 reporting requirements.
Lysis worked with global and local compliance to define equivalence between the different classification regimes including EU MiFID classification, US II and MII classification, Singapore, Hong Kong and other far eastern regimes. Lysis created a classification and equivalence model and implemented this on global on-boarding and customer management systems. This was then used to control the distribution of research to customers and the trading investment activities they could under-take. Furthermore, 15A6 reporting was also enforced for in-scope trades with U.S. customers.
Following a review from the Financial Conduct Authority (FCA) in 2021, and a subsequent letter from the regulator, the client had to address a number of gaps that were identified by the regulator.
A US corporate bank in the UK needing BAU On-boarding resources
A crypto asset custodian based in the U.K. with global reach approached Lysis with the request to assist them with the process to obtain registration from the FCA which would enable them to operate in the UK market as a crypto asset business. Due to the holding company’s strong global footprint, part of the FCA requirements for registration included the need for a UK based money laundering reporting officer (MLRO).
