A major Egyptian bank with UK operations had a requirement to identify possible AML and CTF gaps and suggested improvements.
Corporate, Wholesale and Investment Banking
Financial Crime Framework Review and Enhancement
A maturity assessment was conducted, and a remediation roadmap was produced to map the recommended activities that the bank should engage with. The roadmap was risk-based and shows a suggested priority for the actions. The maturity assessment process had been used as the basis for the development of a six-month resourcing plan. This identified the high-level actions that the bank will implement to further embed the management of risk across the bank and deepen its level of maturity, whilst specifically identifying improvements in systems, controls, policies, processes, and people. Lysis took a risk-based approach to the prioritisation of actions which included both regulatory compliance and significant operational risk weaknesses.
Lysis also provided a permanent executive resource with extensive regulatory experience to oversee the delivery of all the workstreams and regularly liaised with senior management of the bank to provide programme feedback. Specifically, Lysis assisted the client in the following areas:
- Capability and awareness
- Governance and oversight
- Risk appetite and tolerance ratios
- Analysis and reporting
- Assessment and controls
- Information management
- Organisational performance
A major European wholesale and investment bank with global reach was put under a Section 166 order due to regulatory concerns regarding their KYC and AML controls.
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