• Huntswood was engaged by a well-established high cost short term lender who provide consumer credit services including the provision of loans, cheque cashing, gold and foreign currency exchange.
  • We had been chosen to become the firm’s long-term external audit partner to provide ongoing thematic compliance monitoring services. This was based on our subject matter expertise, our position on the FCA’s Skilled Persons Panel and the existing relationship we held with the client.
  • Working with our client, we recommended and agreed a series of both conduct and financial crime reviews to be conducted throughout the year, based on the firm’s key areas of risk. One particular thematic review focused on anti-money laundering (AML).
  • As our client was undergoing major restructuring and a change in strategic direction, the firm’s management team had agreed it was necessary for a review to be conducted of their current AML / know your customer (KYC) framework and supporting policies and procedures.
  • This was to ensure that the firm recognised and mitigated any financial crime risks and had sufficient systems and controls in place to meet relevant regulatory requirements.


Our review incorporated the following activities:

  1. A desk-based review of the pre-visit information provided by the client in response to our data request. This included, but was not limited to, a review of the firm’s existing AML policies and procedures including customer due diligence, sanctions screening and transaction monitoring; risk assessments; governance and oversight of AML including management information; and the training provided to staff
  2. A site visit to the firm’s head office, where we conducted detailed questionnaire-based interviews with key AML staff, reviewed a risk-based selection of customer files and performed walkthroughs of several AML related systems
  3. Site visits to two of the firm’s branches to understand how AML procedures operate ‘on the ground’ and, more broadly, the firm’s face-to-face interaction with customers


  • Following our review we issued a detailed report to the client containing our key findings, associated risks and a series of recommendations for the firm.
  • Our review found that the firm’s current AML systems and controls were sufficient when assessed against current regulatory requirements and applicable standards. However, a number of weaknesses were identified, on which we made specific remedial recommendations to the firm.
  • We have since conducted a follow up AML review as part of the ongoing compliance monitoring plan for our client. We reassessed the firm’s AML systems and controls and whether the firm had implemented the recommendations provided in our previous review.
  • The review provided assurance to the client that their current AML systems and controls met relevant regulatory requirements. The firm now has a robust AML / KYC framework in place with effective supporting policies and procedures to help identify and mitigate financial crime risk.