Financial Crime & Forensics Support Services
Financial crime, money laundering and terrorist financing continue to pose significant and immediate risk to firms. The FCA has stated that, at a minimum, firms must satisfy themselves that they have robust governance, effective risk procedures and adequate internal control mechanisms to manage their financial crime risk.
Firms have specific and prescribed requirements relating to Customer Due Diligence (CDD) and Know Your Customer (KYC), transaction monitoring, the reporting of SARs (Suspicious Activity Reports), managing fraud risks and preventing bribery and corruption. Additionally, developing technology used by criminals are an increasing concern, highlighting the need for firms to have robust preventative measures and monitoring systems in place.
Complyport is the City’s award-winning compliance and regulatory consultancy that has been servicing financial services firms for over 20 years, and our Financial Crime Unit, led by Martin Schofield – one of the world’s leading specialist in the field, brings a wealth of experience to every project we are engaged in.
Our highly experienced financial crime professionals and forensic experts , in subjects such as anti-money laundering, counter terrorist financing, anti-bribery and corruption and fraud and regularly help our clients navigate the complexities of the financial crime and money laundering environment.
Whether you are an established firm looking for guidance, an expert ear/sounding board, temporary resource or assistance, or a start-up needing advice, we are here to help.
AML and CTF – Anti-Money Laundering/Counter Terrorist Financing reviews and health checks
At Complyport, we can assess your current AML and CTF controls and risk framework, matching it against legal and regulatory requirements, industry best practice and your firm’s internal risk appetite, policies and procedures. Following the review and health check, our team will provide confirmation of any areas for improvement and any recommended remediation work.
Implementation of robust AML and CTF controls and frameworks.
Our team is able to assist your firm in developing and implementing robust and proven financial crime prevention controls and frameworks.
With our tried and tested support, our team can help your firm effectively mitigate the adverse effects of internal and external financial crime activity.
Whether internal, external or collusive in nature, the Fraud Act 2006 introduced specific offences relating to fraud, such as:
- false representation
- failing to disclose information when it should be disclosed,
- abuse of a position of trust
- making or being in possession of articles intended for use in fraud.
With fraud not only being an offence in its own right, but also a predicate offence to money laundering, it presents a dual risk to firms, if permitted to go unchecked.
Complyport can help your firm mitigate these risks by the implementation of effective fraud prevention policies and procedures, a review of your fraud prevention controls, or training of your staff.
Anti-Bribery & Corruption
With the risk of enforcement in both the financial and non-financial sectors, it is important that firms have a robust Anti-Bribery & Corruption compliance framework to mitigate the risk of non-compliance by their own employees or those who act as associated parties to the firm,
Similarly, to fraud, bribery too is considered an acquisitive crime and as such serves as a predicate offence to money laundering, and Complyport can help your firm mitigate these risks by the implementation of effective anti bribery and corruption policies and procedures, a review of your anti bribery and corruption controls or training of your staff.
Financial crime topics Complyport assists firms with:
- Financial crime health checks and audits,
- Implementation of financial crime, AML, CTF, ABC, Fraud and market abuse controls and frameworks,
- Ongoing advice on financial crime, AML, CTF, market abuse and fraud prevention,
- Authoring/reviewing financial crime policies,
- Outsourced MLRO support
- Outsourced KYC and CDD support,
- Assistance in identifying Politically Exposed Persons (PEPs),
- Assistance in navigating international sanctions,
- Support with preventing market abuse and insider dealing,
- Expert Witness in Financial Crime cases
- Forensics and Investigations
- Design and/or delivery of online or face to face financial crime training
Key Regulatory Focus – Vulnerable Customer Management
Vulnerability comes in many guises and can be permanent or temporary and can affect anyone at any time. The identification and effective management of vulnerable customers is essential and has been the topic of numerous FCA communications since 2015..
The importance of an effective vulnerable customer management framework, including appropriate policies and procedures in undeniable. However, there can be intrinsic links to vulnerable customer management and fraud, bribery, data protection and money laundering.
Criminals are well versed in regulatory requirements and expectations, and as such could be using alleged vulnerabilities to hide and disguise the commission of fraud against a firm.
Equally, those within a firm with access to customer data, ie which customers have been classified as vulnerable, pose a significantly increased risk of being bribed by criminals to release that list Not only would the release of such information result in a breach of the UK Data Protection Act 2018/GDPR, it must also be remembered that whilst fraud and bribery are criminal offences in their own right, they also serve as predicate offences to money laundering.
Essentially, vulnerable customer management can be broken down into 4 categories:
- What the regulator wants and expects
- What the customer wants or needs
- What the law requires
- What your staff want and deserve.
Complyport can help guide you through the financial crime minefield, ensuring that you do not do wrong trying to do it right. We can undertake health checks or audits of your policies and procedures relating to vulnerable customer management, or help to deliver training on the topic to your staff. Training is and will continue to be vital if you are to successfully navigate the requirements of the 4 categories above.
Our vulnerable customers gap analysis can help ensure your company has the correct policies and procedures in place, as well as the practical steps to be taken once identified. Our specialist team can implement an evaluation and monitoring process to assist in your efforts to remain compliant and continue to protect your vulnerable customers.
How can we help?
Our extensive experience and expertise across financial crime prevention can help protect your firm and your customers. The experience within Complyport’s team enables us to help you develop and understand the holistic approach to financial crime risk management, which is an essential tool required in today’s armoury to help counter the risk of financial crime.
The importance of countering financial crime risks has been highlighted by the FCA’s Financial Crime Guide (FCG), stating that all firms must take steps to defend themselves against financial crime, with effective systems and controls to detect, prevent and deter.
Complyport offer a range of services to ensure your firm remains protected against financial crime, and compliant with ever evolving legal and regulatory frameworks. From conducting audits to training employees, our Financial Crime and Forensics Unit offer a variety of services, all of which can be tailored to your firm, to help meet your needs and requirements to safeguard your firm.
Interested in learning more about our services?
Please fill our free consultation form and a member of our team will get in contact with you.