Financial Crime remediation programme for the UK subsidiary of an overseas bank

The bank was subject to a multi-stage Financial Crime Skilled Person review with a specific focus on compliance with Money Laundering Regulations. The bank was also subject to a VREQ restricting onboarding of new customers. We were asked to provide assistance in various aspects of the bank’s remediation programme arising from the Skilled Person recommendations.

One main area of focus was supporting the bank with review, QA, remediation and resolution of their customer base (Personal, Corporate and Correspondent Banks). This included provision of experienced project and Financial Crime subject matter expertise (SME); developing bespoke processes for customer file remediation; creation of project governance and reporting; mobilisation of project team from existing 1LOD/2LOD teams within the bank; and provision of training and ongoing coaching to develop and maintain standards.

We recognised that the best way to fulfil the task and help the bank to achieve sustainable change was to ensure that they had full ownership for the programme. We achieved this through putting their staff at the heart of the project and providing targeted programme management and SME support. The programme was mobilised and running within three days and included formal governance structures; regular dialogue with the bank’s senior leadership; ensuring ongoing knowledge transfer to key individuals in the bank through ‘how-to’ guides, training, workshops and ongoing on-the-job coaching.

We also supported the bank in preparation for Skilled Person stage visits including: awareness sessions; practice interviews and process walkthroughs; support in preparation of a Skilled Person data room; and conducting debriefs.

The bank were able to remediate their entire customer base ensuring all documentation was in place. The firm’s processes were enhanced and their staff emerged with an enhanced knowledge and appreciation of Financial Crime Compliance. The firm has successfully completed their remediation, exited the Skilled Person process and are now able to onboard customers again.