Case Study

Remediation Project

Results at a glance

  • Rapid Deployment of skilled remediation resources
  • Accelerated project completion
  • Assured Stakeholder Management

Overview

Our client is an established regulated business which has enjoyed the benefits of a significant growth story. The Company’s business model is to offer a frictionless onboarding solution for customers who are in need of access financial products and services. The model included a heavy reliance on post-onboarding monitoring activity to manage financial crime obligations.

This model possesses significant downstream risk in the form of potential financial crime reporting obligations, with a high incidence of cases being referred to the company’s financial crime team for potential escalation to the National Crime Agency (“NCA”).

“…support activities included deploying a team of skilled individuals to support the existing team to clear all outstanding cases.”

Our Approach

We were engaged to conduct a regulatory health check examine ways of reducing the high volume of cases being referred to the company’s financial crime function.

Our review revealed that, while the policies were broadly fit for purpose, a mis-reporting of the age profile of cases led to potential concerns that vulnerable customers may be affected by the delays in dealing with the reports that were being received.

Results

We supported the client with initial communications to the FCA, and other key stakeholders, and in designing an approved project plan to eliminate outstanding cases.

Our support activities included deploying a team of skilled individuals to support the existing team to clear all outstanding cases, establishing a process for the efficient and timely submission of SARs to the NCA and the prompt return of funds to vulnerable customers who may have been the victim financial crime.

We were able to assist our client with eliminating the outstanding cases within one month, thereby eliminating a significant regulatory exposure while at the same time, through sensitive and appropriate dialogue with the FCA, helped our client avoid regulatory censure.