Our client thought it was business as usual -- the Financial Conduct Authority (“FCA”) was visiting this financial company on a routine supervisory visit.
However, the supervisors raised serious concerns about the adequacy of the company’s financial crime systems and controls. The FCA immediately imposed a restriction stopping the intake of new business and demanded that our client commission an independent review of its anti-financial crime framework.
We were brought in immediately and dived in behind the scenes, performed a gap analysis, made recommendations for ‘quick fixes’ and updated policies and procedures. With a week to go before the FCA would return, we conducted interviews with key staff to test their understanding of their controls and the relevant regulatory obligations, identified areas for improvement and provided coaching. This allowed the client to focus internal resource on remediating areas of highest impact. As a result of our quick activation and careful efforts to revise the client’s systems, the FCA lifted the restriction.