A financial crime framework that satisfies the FCA and banking partners
A growing payments firm needed anti-money laundering controls that would satisfy both its banking partner and the FCA. MEMA built the risk assessment, controls and monitoring end to end.
- PassedBanking-partner due diligence
- End to endRisk assessment to staff training
The challenge
The firm's customer base was growing faster than its anti-money laundering controls, and a banking partner had started asking hard questions. Without a defensible framework, it risked losing that 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 we 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
- Set up transaction monitoring and a clear route for reporting suspicious activity 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
The outcome
A financial crime framework that passed the banking partner's due diligence and held up to FCA scrutiny.
Framework built and operational, then maintained as the firm grew.
Client details are presented to protect confidentiality. Outcomes reflect specific engagements and are not a guarantee of results, as every firm's circumstances differ.
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