Case Study – Anti-money Laundering Process Assessment

Our client was a global investment services and securities firm with head offices in South America and business operations in London and New York.

Our assignment was to assess the Firm’s compliance with UK Anti Money Laundering arrangements applicable to its UK based broker-dealer and investment management operations.  The review covered:

  • Compliance with the UK Anti-Money laundering laws, rules and regulations
  • Anti-Money laundering policies and procedures adequacy and approval
  • Arrangements for Customer Due Diligence (including foreign bank account, shell banks and PEP due diligence)
  • Arrangements for the confirmation that the firm does not hold clients’ assets and monies
  • Arrangements for the detection and/or reporting of suspicious activities
  • Arrangements for MLRO notification, escalation procedures and annual reporting
  • Adequacy of the Firm’s training program.

The review involved discussions with the MLRO, AML Officer and Compliance Officer regarding the AML Program and independent compliance oversight, review and testing of arrangements for Customer Due Diligence and for the detection and/or reporting of suspicious activities, interviews with relevant senior management and personnel and review of documentation provided. Reports were provided on our observations and findings for the separate broker-dealer and investment management operations.

The key complexity was that the clients KYC checking was conducted by a team based in South America. Cordium ensured that materials were made available to consultants in London in order to confirm the veracity of the information provided. The project was completed to the client’s satisfaction within the forecast budget.

 Cordium has extensive experience of financial crime compliance consulting. A core service of the Firm is the provision of compliance infrastructure (manuals, policies and procedures) that meet all UK compliance requirements, including financial crime, anti-bribery and corruption, market abuse, insider trading and anti-money laundering conduct compliance in the investment management sector. Cordium provides regular financial crime related training to investment management firms covering anti-money laundering and market abuse.