Multi stage Skilled Person Report relating to the financial crime systems and controls of a retail and commercial bank
This internationally owned bank had a focus on retail, corporate and correspondent banking, treasury and global markets and trade finance. The bank was undertaking a programme of remediation due to regulator concerns over its financial crime systems and controls. It was also subject to onboarding restrictions. The regulator required a Skilled Person to report on progress of remediation and, once complete, the sustainability of the remediation. The regulator also wanted to assess the extent to which there was a sustainable culture of financial crime compliance in place.
We assembled a team based on the specific nature of the regulator concern. This team included several senior staff with extensive experience of areas such as:
– Financial Crime (in particular Money Laundering) regulatory requirements;
– Financial Crime systems and controls;
– UK and international retail, corporate and correspondent banking; and
– organisational development / culture professionals.
We adopted a strictly evidence-based approach to the assessment including document review; interviews with key officers, managers and staff; live observation of Board, governance and remediation committee meetings over a period of several months; operational process walkthroughs; and sample testing of due diligence on customers.
Our work focused on areas including governance, skills and capabilities, policies and procedures, risk assessment, compliance monitoring, due diligence processes, screening processes, and training and awareness. We also assessed the activities and mechanisms in place to promote / enable a good Financial Crime culture and evaluated how this culture manifested in the business.
We triangulated the results of these various sources of evidence to arrive at robust conclusions supported by clear evidence.