Investment, Asset & Wealth Management

The Lysis Group can assist firms in the asset management industry ensure compliance with evolving regulatory requirements including mitigation of financial crime risks and maintaining the integrity of their operations.

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In the UK and EU we have extensive experience of compliance with all key regulatory requirements including the Undertakings for Collective Investment in Transferable Securities (UCITS) Directive, the Alternative Investment Fund Managers Directive (AIFMD) and MiFID II (the Markets in Financial Instruments Directive II).  In the UK we additionally support compliance with the Financial Services and Markets Act 2000 (FSMA) and with the requirements defined in the Financial Conduct Authority (FCA) Handbook, such as AML and CASS. In the United States we are familiar with compliance with regulatory requirements including the Investment Company Act of 1940, the Investment Advisers Act of 1940, the Securities Act of 1933, the Securities Exchange Act of 1934 and the Dodd-Frank Wall Street Reform and ConsumerProtection Act. We are also familiar with the regulatory approach of the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA).

We are experienced in working across the network of firms involved in the industry including Asset Management Firms, Custodian Banks, Fund Administrators and Transfer Agents. For example:

For asset management firms we have:

  • Conducted third-party due diligence on the compliance work done for them by fund administrators and transfer agents.
  • Carried out due diligence on the counterpartiesin new portfolios, post-acquisition.
  • Provided our full on-boarding and review managed service on an on-going basis.

For custodian banks we have run 2nd Line of Defence and 1st Line of Defence compliance programmes.

For fund administrators and transfer agents we have run on-boarding for complex portfolio take-on programmes, including complex structures involving multiple layers of entities, making it challenging to trace the ultimate beneficial owners and assess the associated risks.

In the above situations we have deal with:

  • High Volume of Transactions: The high volume and frequency of transactions in fund management require robust monitoring systems to detect suspicious activities without causing delays in operations.
  • Cross-BorderOperations: Fund managers frequently operate across multiple jurisdictions, each with its own AML regulations, creating a need for comprehensive compliance strategies that address diverse regulatory requirements.
  • Evolving Regulatory Landscape: The regulatory environment for AML is continuously evolving, requiring fund managers to stay updated with the latest changes and ensure their AML programs are adaptable.
  • Integration of Technology: Implementing advanced technologies such as AI and machine learning for AML compliance can be challenging due to the need for significant investment and the integration with existing systems.

Consulting & Advisory services

Lysis specialises in AML/CFT Risk Management Framework creation and enhancement, assisting fund managers to:

  • Create or enhance a Business Wide Risk Assessment which applies a holistic view to the firm’s exposure to money laundering and terrorist financing risks.
  • Develop Customer Risk Rating Methodologies tailored to the fund management business in terms of which they are able to identify and risk-assess their Customers/Counterparties and including funds, sub-funds and various agents.
  • Design and implement appropriate risk controls to effectively manage their AML risk.
  • Create or enhance AML Policies and KYC/Customer Due Diligence Procedures tailored to the fund management industry aligned with relevant regulations and best practices.

View our Optimisation of Financial Crime Processes insight

We are highly experienced in Cross-BorderOperations, each jurisdiction with its own AML regulations, creating a need for comprehensive compliance strategies that address diverse regulatory requirements.

Lysis can provide ongoing advisory services, including horizon scanning services, thereby ensuring that fund managers remain up to date with changing AML regulations and industry best practices.

We can support new entrants to specific jurisdictions by assisting firms to navigate the regulations and build a strong relationship with the relevant regulators.

Lysis can provide advice to fund managers on how to achieve cross border compliance in their interactions with other jurisdictions in the EU, US, UK, etc.

Lysis can support firms ensure compliance with sanctions regimes by creating robust sanctions screening policies and procedures.

We are well plugged in to the Evolving Regulatory Landscape for AML which is continuously changing, requiring fund managers to stay updated with the latest changes and ensure their AML programs are adaptable.

Lysis Anti-Financial Crime specialists can ensure compliance with relevant regulatory requirements and industry best practice by conducting regular independent reviews of the fund manager’s AML programs and AML Risk Controls Framework: gaps can be identified and recommendations for improvement provided.

We offer short Health Checks and more in-depth Maturity Assessments, learn more here.

Regular stress testing of the firm’s AML controls against risk frameworks will help maintain compliance with regulatory expectations and Board peace of mind.

Lysis’ CLM consulting services include Target Operating Model (TOM) definition, systems and data source selection and implementation and CLM process efficiency improvements.  We also have the necessary skills and experience to assist your firm to compile, review and optimise FC controls across the entire funds CLM process since we focus on the overall chain of client/counterparty activities. The objective is to encourage retention, improve customer experiences, and maximise profitability for the firm while remaining fully compliant.

We are familiar with the the high volume and frequency of transactions in fund management which require robust monitoring systems to detect suspicious activities without causing delays in operations.  We are also familiar with Integration of Technology and implementing advanced technologies such as AI and machine learning for AML compliance.

We can assist firms to assess the efficiency of their CLM operating model and processes and embark on a programme of realignment followed by transformation and optimisation.  The method focusses on people, process and technology over a 2-3 year timeline.  We have seen efficiency gains in excess of 55%.

CLM/ AML Middle & Back Office services

The business operations division of the Lysis Group, can assist fund managers in the following ways:

Lysis can provide regulatory experts to provide temporary or more permanent MLRO guidance and oversight.  We can also provide interim MLROs/DMLROs.

Lysis SMEs can assist with the preparation and submission of Suspicious Transaction Reports (SARs/STRs) and other regulatory submissions.

Lysis can also support fund managers to manage their relationships with regulatrs by means of direct communication with the regulator, responses to compliance inquiries or audit inspections.

Lysis SMEs can perform review and QA of the AML programmes run for fund managers by their fund administrators and other agents.

Performance of transaction monitoring activities aligned with relevant regulatory requirements.

Identification of Suspicious Transactions and writing of Suspicious Transaction Reports (SARs/STRs).

Ongoing monitoring of existing customer base against industry best practice sanctions, PEPs and adverse media databases.

Event Driven Reviews allow for a full refresh of Customer KYC when a significant change or potentially suspicious activity has been detected.

Periodic Reviews of existing Customer KYC in line with AML Risk Rating.

Ongoing TM reviews to identify any suspicious activity in customer accounts.

Our analysts are experienced at dealing with the high volume and frequency of transactions in fund management without causing delays in operations.

Screening of new and existing customers against international sanctions data bases to ensure compliance with both international and Irish/ EU sanctions regimes.

Screening of transactions to identify possible sanctions infringements.

Our award-winning managed service offering is fully configured to suit firms' individual risk appetites and operational controls and is perfectly adaptable to meet firms’ policy requirements in a dovetailed manner.  This provides full AML compliance to local regulations “in a box”.  We provide the people, processes and technology to on-board, monitor, review and off-board portfolios/customers/counterparties.

Our Managed Service can be combined with our 2LoD - MLRO Support & Interim MLRO/DMLRO service to provide a complete CLM and AML operation.

Customers for this service include various investment funds.

View our An Award-Winning Managed Service Offering insight.

Training & Capability Development services

Lysis Academy can support your firm’s specific staff training needs by providing:

  • AML/CFT training tailored to the risks in the fund management business. All staff, not just those in Compliance functions, need to understand their responsibilities with regards to the prevention of money laundering and financial crime.
  • Ongoing training and staff education.

Related Case Studies

Corporate and Counterparty KYC Remediation and Golden Data Source Creation for a Global Inter-dealer Broker

A major bank with two major trading entities wished to decrease time-to-trade processing overheads for new customers and for new products for existing customers.
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KYC Utility Strategy for a large Operator of Bank Infrastructure

A large operator of bank infrastructure wanted to develop a shared operating model and managed service for client lifecycle management (CLM), anti-money laundering (AML) and Know Your Customer (KYC).
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Delivering fully outsourced and secure KYC operations

The client is incorporated in Ireland as an Irish Collective Asset-management Vehicle (ICAV). The client is an American investment fund which specialises in lending large amounts of money to various entities ranging from listed entities to unregulated entities based in the USA.
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Operations & Resourcing

Market Abuse Legislation Review and MLRO Support

A prominent security services firm that forms part of a French multinational investment bank and financial services company asked Lysis to assist with the securities/back-office function within the multinational investment bank.
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Experts in this Industry

Jon Sweet

Chief Executive Officer

Jon has 35+ years’ wholesale financial markets experience in London, New York, Singapore and Frankfurt. He specialises in Regulatory Strategy, Governance, Regulatory Change Management and M&A/Integration. Jon founded Lysis in 2001. He was previously Head of the Investment Banking, eBusiness and Trading Floor practices at AIM-listed TCA Consulting. Notable clients include Deutsche Bank, BNP Paribas, RBS/ABN, ICAP, JCB cards and Uphold.
Group Board
Group Management Team

Wendy Murray

Head of South Africa Operations

Wendy has more than 18 years’ experience within regulatory operations and financial crime compliance.
Group Management Team

Anne-Maria Rothenstein

Non-Executive Director

Group Board
Advisory Panel
Associates Panel

Lynn Hurlston

Senior Associate

Associates Panel

Partners to help us deliver excellent services

Lysis works with a number of like-minded niche funds management specialists to supplement and enhance our services to the funds and investment management industry.

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