A financial-crime framework that stands up to FCA and banking-partner scrutiny

The challenge

The firm was scaling its customer base faster than its anti-money-laundering controls, and a banking partner had started asking hard questions. Without a defensible financial-crime framework, it risked losing that banking relationship and falling short of FCA expectations.

Regulatory context

Money Laundering Regulations 2017, JMLSG guidance and SYSC 6.3, alongside the FCA's financial-crime expectations and the due-diligence demands of banking and safeguarding partners.

What MEMA did

• Produced a business-wide risk assessment covering the firm's products, customers, channels and geographies
• Designed proportionate KYC and customer due-diligence procedures for onboarding and ongoing review
• Stood up transaction monitoring and a clear suspicious-activity-reporting route to the MLRO
• Supported the MLRO with policies, governance and a board-level reporting line
• Delivered staff training so the controls were understood and used day to day

Timeline

Framework built and operational, then maintained as the firm grew.

Outcome

A financial-crime framework that satisfied the firm's banking-partner due diligence and held up to FCA scrutiny.