Provision of interim MLRO to consumer investments firm
The Firm provided custody and execution-only dealing services to Eligible Counterparties, Professional Clients and Retail Clients. The businesses primary model served Professional Institutional clients directly or their underlying clients indirectly. The Firm required an interim MLRO at short notice due to a departing member of staff.
A further challenge for the business was that they were under scrutiny by the FCA. Whilst there was no Skilled Person review in place the Firm had received a detailed feedback letter which was critical of their Financial Crime framework and they were therefore undertaking a detailed remediation exercise including a review of their client base. At this time, they were also subject to Voluntary Requirement (VREQ) restrictions affecting its ability to onboard new clients.
We provided the Firm with details of potential candidates from within our team to undertake the Interim role. In each case we ensured the candidate had: Deep subject matter expertise in Financial Crime; An understanding of the roles and responsibilities of the MLRO; 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 and supported the Firm with their remediation process. The tasks undertaken included:
• Conventional roles and responsibilities of an MLRO (SMF 17);
• Helping the Firm set up its detailed remediation plan and undertaking tasks on a priority basis;
• Fulfilling on priority requests from the FCA and helping enhance the Firms engagement with the FCA;
• Overseeing customer file remediation;
• Providing a handover briefing to the new permanent MLRO when they joined.
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 remediation review underway.
