Skilled Person Review of firm’s ability to address issues and deficiencies within its Financial Crime framework

The Firm is a multi-platform Electronic Money and Payment Institution (EMI) with circa 3,000 employees across Europe. Our focus was three key FCA regulated UK entities.

The FCA had a concern, due to recurring issues in Internal Audit reviews, that the Firm was not adequately remediating and resolving issues and deficiencies identified in its FC Framework (either on a timely basis or at all).

Our review included evaluating the completeness of circa 150 recommendations identified in relevant scope Internal Audits over a period of three years for the three entities.

In doing so we evaluated the appropriateness of the Firm’s action plans that had been developed to address issues and deficiencies identified within the Firm’s internal audit reports, including an assessment on the quality of these actions in response to demonstrate that the Firm can manage and mitigate exposure to Financial Crime risk effectively.

We also evaluated whether the remedial work undertaken was appropriate to ensure the Firm’s FC systems and controls were compliant with legal and regulatory FC requirements. We evaluated both Design and Operational Effectiveness.

We worked closely with the Firm in particular with the sponsoring Board Members, 2LOD and 3LOD teams to ensure the recommendations captured were proportionate to the business and could be maintained on a sustainable basis.