A UK-crypto asset subsidiary of a Nasdaq-listed firm in the U.S. has a requirement to review their anti-money laundering (AML) policy framework and idetify possible gaps in line with FCA requirements.
Crypto & Digital Assets
UK-crypto asset subsidiary of a Nasdaq-listed firm in the United States.
This called for a health check which consists of a high-level review of the design of a firm’s FC framework to identify problem areas.
Lysis reviewed the client’s policy framework and made recommendations for uplifting the policies based on identified gaps. From a content perspective, this included a review to determine if the policies are documented and aligned with the firm’s standards across all the business sectors.Testing of the controls can only take place once all the policy recommendations were embedded into the client’s policy framework. Ineffective policies by design will result in ineffective implementation and this will impact the testing of controls negatively.
Lysis provided the client with a detailed report that contained the findings of the review. The report helped the firm to conduct a gap analysis against their current approach to AML and current regulatory requirements which allowed the firm to gain a detailed and independent understanding of its AML governance framework.
Our client had a requirement to train some experienced operational staff in AML
Our client had identified a tranche of several thousand corporate and retail customers for which they wished to remediate the Know Your Customer (KYC) data held and to re-assess whether the interactions with the retail customers were compatible with Responsible Gambling requirements.
Our client was looking at options for the location of new Level 2 teams to support retail customers with affordability and suitability issues.
