Provision of interim MLRO to payments firm

Our client, a UK headquartered payment services provider with an international business and offices, required an interim MLRO at short notice due to a departing member of staff.

In addition to the Business as Usual activities required of the MLRO, the business was subject to an ongoing multi-stage Skilled Person Review, had a remediation plan that was still underway and was subject to Voluntary Requirement (VREQ) restrictions affecting its ability to onboard new customers.

We provided the Firm with a series of potential candidates from a combination of our own Financial Crime team and other external contractors we had worked with on an ongoing basis. As part of this we ensured each candidate had:

• Deep subject matter expertise in Financial Crime;
• An understanding of the roles and responsibilities of the MLRO (either through direct experience or from an advisory standpoint);
• Experience of Skilled Person processes and subsequent remediation exercises.

The Firm undertook an interview process and selected the candidate that was best suited to their needs.

Over the course of a 6-month period our team member undertook the MLRO role including providing oversight to the Firms 2LOD team; assessment and approval of escalated decisions; communications with regulators, banks and service providers; and dealing with ongoing internal queries. They also took responsibility for delivery and completion of key parts of the Skilled Person Review remediation programme.

The Firm was able to maintain an experienced MLRO presence during the interim period up to their next permanent hire which was especially important due to the Skilled Person review being underway.

During this time, they were also able to expand and enhance the skills of the Firms core team leaving a stronger resource in place than when they had started. The remediation programme was also substantially completed except for areas where the Firm needed elapsed time to demonstrate operational effectiveness.