• We were contacted by a large complex overseas bank to complete a number of independent Financial Crime Risk (FCR) enhanced due diligence reviews, with a heavy focus on anti-money laundering (AML) and counter-terrorist financing (CTF).
  • Our client wanted to undertake the reviews as they were expanding their business strategy and were keen to develop their portfolio of clients who possessed a higher inherent AML risk. This included a number of Money Service Businesses (MSBs).
  • Therefore, before the commencement of any business relationships, the firm wanted to satisfy itself that these higher risk clients had both adequate and effective systems and controls in place to mitigate possible legal, regulatory and reputational risks. These risks included but were not confined to fines, prosecution and reputational damage.


  • Our reviews were split into 3 phases:
    • In phase 1 we conducted an independent assessment of the adequacy of the MSB’s FCR systems and controls, against set criteria benchmarked against industry good practice and the legal / regulatory requirements and expectations set out by the FCA, HMRC and the Joint Money Laundering Steering Guidance (JMLSG). This included, but was not limited to, a review of: governance; risk assessment; training; policies and procedures; full customer due diligence (CDD) (initial and ongoing); monitoring and testing; and MI and reporting.
    • In phase 2, we completed an on-site visit to the MSBs to test the findings from Phase 1 and to determine whether their AML systems and controls were effective. This comprised a review of documentation held on-site, such as suspicious activity reports and transactional data, and interviewing key members of staff.
    • Phase 3 included tailored re-reviews for each MSB to ensure the recommendations made had been effectively implemented.


  • After reviewing the MSBs, we completed a detailed enhanced due diligence report outlining:
    1. Key FCR risks, assessing and weighting these risks under a bespoke rating methodology
    2. Recommendations for remediation
  • Since the start of our engagement, we have completed a number of reviews and our client was able to use the report as part of their risk management decision making process to determine whether it was within their risk appetite to commence or continue a business relationship with the MSBs. As a direct result of our reviews, our client has been able to successfully onboard business relationships with a significant number of the MSBs we have assessed.