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.
A U.K. Branch of a major Asian bank needed an in-depth review and enhancement of their AML governance framework. Lysis conducted a success review and drafted all required policies & procedures, and established a KYC Target Operating model.
A newly established digital bank required full regulatory permissions to operate as a licensed bank in the UK and to ensure compliance with EU PSD2 regulations.
Our client had been advised that their AML provisions were not up to the required standard and wished to remedy this before regulatory sanctions were imposed.
