Anti-Money Laundering (AML) Controls
UK Headquartered Retail Bank
In response to a Financial Conduct Authority (FCA) Systematic AML Programme (SAMLP) review, a large UK Retail Bank engaged one of the Gracechurch Co-Founders to coordinate a £190m programme to uplift the bank’s Anti-Money Laundering controls. Over the next three years, the Gracechurch Co-Founder successfully directed the creation of both new AML controls and the upgrade of existing enterprise-wide AML controls, specifically;
• Drafting of a new Anti-Money Laundering and Counter Terrorist Funding Policy, which included on-boarding standards, and both time and trigger based Know Your Customer (KYC) requirements;
• Definition of a Customer Risk Assessment (CRA) methodology, and the creation of a CRA utility for use in all on-boarding and KYC processes;
• Upgrade of the Transaction Monitoring system;
• Upgrade of the Sanctions and Embargoes controls for both customer screening and payments screening;
• Creation of a Financial Crime Intelligence Unit, directly supporting the UK Government’s establishment of the Joint Money Laundering Intelligence Taskforce.
In additional, the Gracechurch Co-Founder, in conjunction with the Group Money Laundering and Reporting Officer, supervised the successful embedment of the new Anti-Money Laundering and Counter Terrorist Funding Policy in each of the bank’s operating divisions, including;
• Implementation of on-boarding standards across all distribution channels;
• Implementation of time-based and trigger-based KYC reviews for all customer segments;
• Remediation of all KYC files to the uplifted standards;
• Creation of a KYC utility for personal customers and small / medium size enterprises, utilising trusted public sources of intelligence to enable continuous, automated KYC.
The success of the programme was evidenced through the subsequent FCA Annual Firm Evaluation Letter which down-graded the bank’s overall Financial Crime risk.