A large U.S. based end-to-end human resources management firm and Lysis delivered a solution for the newly established UK/EU subsidiary which forms part of the SEC regulated entity.
Payment Services & Card/ Merchant Acquirers
Financial Crime Framework Review and Enhancement
The client asked Lysis to assist them in ensuring that their UK/EU subsidiary based in the UK is aligned with UK and EU regulatory requirements. This included establishing an Anti-Money Laundering (AML) framework which consisted of drafting applicable AML and Counter Terrorism Financing (CTF) policy, drafting a Sanctions policy, drafting a transaction monitoring procedure and delivering the financial crime (FC) governance framework. The FC governance framework consisted of a risk appetite statement, and associated metrics, and their Management Information (MI) reporting process and the governance structure to facilitate effective decisions. Lysis was also asked to conduct a financial crime risk assessment (FCRA) which identified the inherent AML/CTF and Sanctions risks and recommended proportionate controls needed to mitigate these risks.
The level and the quality of professional services provided by Lysis met and exceeded the client's expectations. As a result, Lysis was appointed to further assists the client throughout the period of growth which included the design of the readiness roadmap for the launch of their product, in the UK and then EU. Three high-level requirements were delivered successfully during this project, and these included:
- The development and design of an effective and proportionate FC (AML) framework.
- The development and design of the FC governance structure. Setting up sustainable MI processes and conducting a financial crime risk assessment.
- The delivering of the high level FCRA which recommended proportionate FC controls.
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.
A major wholesale and investment bank with global reach was placed under a Section 166 order regarding their KYC and AML controls.
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.
