The challenge
An FCA regulated client was in the process of having an AML audit conducted by a consultancy firm in preparation for an FCA interview. At the last minute, the consultancy firm pulled out of completing the audit, leaving the client without a final report or any information to assist with the interview.
The client was aware of Thistle Initiatives’ reputation in the industry and its longstanding experience providing support for FCA regulated firms. It then approached Thistle Initiatives with the challenge of a tight turnaround requirement; the team rose to the challenge and an audit was quickly underway.
The solution
The Financial Crime team first met with the client to understand the client’s needs, the audit scope required, the client’s products and services, the governance framework, and the parties involved as well as the time available to complete the audit. A mutually agreed timetable was then formulated and implemented with clear instructions on the interview process.
Prior to the audit interview, a document request agenda was supplied to the client to obtain a suite of documents within the AML framework to be reviewed and analysed by the Financial Crime team. The Financial Crime team reviewed the documents and also interviewed parties involved in each part of the AML process; from onboarding and customer due diligence to suspicious activity reporting to board / senior management responsibilities and governance.
All audit modules were thoroughly reviewed and assessed against the UK regulatory framework, including the Joint Money Laundering Steering Group Guidance (JMLSG) and the FCA Handbook.
Whilst conducting the audit, the Financial Crime team also provided the client with a guidance document and training sessions for preparing for an FCA interview to ensure the client was comfortable, confident, and thorough in responding to interview questions.
The result
The client was provided with a detailed AML Audit report outlining the areas for improvement including a detailed management action plan for those deficiencies identified through the audit process. The report was then utilised as part of the FCA interview process as an external audit review and Thistle was identified as a partner to support with compliance guidance and assistance.
The client was delighted with the process, the outcome and the timely fashion in which the support was provided by the Financial Crime team. The client has since signed up for continued compliance support /assistance with Thistle Initiatives, to ensure it does not go through a similar ordeal in the future.
Visit our Financial Crime page for more information on our services.
Contact us on 0207 436 0630 or email info@thistleinitiatives.co.uk.