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.
Although the client is based in the US, they have European subsidiaries which include the UK and therefore required Financial Conduct Authority (FCA) registration. In order to obtain registration as a crypto asset firm in the U.K. they had to comply with specific FCA requirements.
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.
A major wholesale and investment bank with global reach was placed under a Section 166 order regarding their KYC and AML controls.
