The Challenge:
A leading UK-based consumer credit and mortgage retailer, part of a US parent group, engaged Huntswood to deliver a two-year compliance monitoring programme covering both regulatory conduct and financial crime. As part of this ongoing review of the client’s systems and controls, Huntswood was tasked with assessing the adequacy of the firm’s overall compliance plan and conducting deep-dive evaluations of its Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) frameworks, ensuring alignment with all relevant legal and regulatory requirements.
Our Solution:
Huntswood delivered a comprehensive review through a combination of desk-based analysis and on-site assessments:
- Desktop Review: We examined all documentation provided by the client in response to our data request. This included policies and procedures covering customer due diligence and onboarding, sanctions screening, transaction monitoring, risk assessments, governance and oversight (including management information), and staff training materials.
- Head Office Visit: At the firm’s headquarters, we conducted detailed questionnaire-based interviews with key AML personnel, reviewed a risk-based sample of customer files, and performed walk-throughs of several core systems to understand operational effectiveness.
- Branch Visits: We visited two branches to observe how compliance procedures were implemented in practice and to gain insight into the firm’s face-to-face customer interactions.
The Results:
Following our review, we delivered a comprehensive report outlining key findings, associated risks, and actionable recommendations. Our assessment confirmed that the firm’s systems and controls were broadly aligned with current regulatory requirements and industry standards.
However, we identified several areas for improvement and provided targeted remedial recommendations. As part of the ongoing compliance monitoring programme, we later conducted a follow-up review to evaluate the implementation of these recommendations and reassess the robustness of the firm’s controls.
This process gave the client assurance that its compliance framework continued to meet regulatory expectations while enabling enhancements to strengthen future practices and maintain a sustainable compliance monitoring programme.