Since Money Laundering Regulations came into force regulatory compliance has become more challenging, because of new requirements and changes to existing obligations.
Our FinCrime consultants have many years’ experience in the field of financial crime prevention and international financial sanctions legislation. We help a broad range of firms across the following sectors, with a special emphasis on those organisations for whom financial crime is especially complex and demanding:
- Capital Markets
- Consumer Credit
- Payment Service Providers
How we can support you
If your firm is subject to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) then all of our FinCrime services are relevant to you.
We can assist with any FinCrime-related remediation work resulting either from a review undertaken by us, or those by other parties, for example, following a s.166 skilled person review. Fees are dependent on the nature of your specific requirements, and we are happy to discuss these with you and agree a plan of action at any time.
Trying to undertake remediation projects using only internal resources can become overly burdensome and a false economy for firms. Cosegic can relieve that burden and also undertake the project from a third-party perspective, ensuring full compliance with the regulations and clear reporting. This leaves our clients free to get on with their day-to-day business.
There are several FinCrime-related remediation projects that may be required by firms. However, the projects we see most often are policy and procedure remediation, and existing customer file remediation.
For policies and procedures, we will work through the firm’s documents and not only ensure they are fully aligned with the regulatory requirements, but also that they are in line with the firm’s own internal systems and controls, as determined by the risk self-assessment.
For existing customer file remediation, we utilise the MCC FileChecker system. FileChecker can be aligned with our client’s specific review requirements, and we provide the right amount of expert resource to conduct the reviews within an agreed deadline, and report back. Fees for existing customer file remediation are dependent on the nature and number of files and are determined following a short sample file review.
FinCrime Assurance Review
A FinCrime Assurance Review is an independent, external review of your firm’s policies, procedures and internal controls in relation to its arrangements to detect and prevent financial crime, such as fraud, money laundering and terrorist financing. Typically, to ensure continuing compliance with the regulations, firms seek such an independent review on an annual basis.
The purpose of a FinCrime Assurance Review is, therefore, to assess the firm’s level of adherence to the applicable regulations and guidance in the UK.
Our FinCrime Assurance Review has been designed to satisfy requirements under UK Financial Crime prevention legislation.
As well as assessment of your written policies and procedures, we will also conduct hands-on testing of your systems and controls, and interview key staff, to evaluate how these are carried out in practice.
You will receive a detailed FinCrime Assurance Review report which will outline our findings, identify any gaps, and provide recommendations for action to address them. This will provide evidence of compliance with the applicable regulations and guidance and allow areas of improvement or remediation requirements to be identified and actioned.
Transaction Monitoring Assurance Review
Although transaction monitoring is included in our FinCrime Assurance Review, some firms may require an even deeper dive into their Transaction Monitoring processes. Therefore, we offer a standalone assurance review of your Transaction Monitoring system, including rules set, thresholds and discounting of a sample of alerts. We will assess your Transaction Monitoring policies and procedures and self-assessment of associated risk. We will also conduct a walk-through of your escalation processes.
You will receive a Transaction Monitoring Assurance Review report which will outline our findings, identify any gaps, and provide recommendations for action to address them. This will provide evidence of compliance with the applicable regulations and guidance and allow areas of improvement or remediation requirements to be identified and actioned.
In addition to reviewing and remediating your FinCrime policies, procedures, systems and controls, we provide standard and bespoke workshop training sessions. These are typically delivered via live video due to many firms now adopting a hybrid working policy, however, we are happy to deliver in person where required. Including live workshops into your annual training schedule improves knowledge retention of staff as they can interact with the trainer, asking questions relevant to their role.
If you require a bespoke workshop, we are happy to discuss your specific needs and create this for any topic related to FinCrime.
In order to properly embed learning, all live training workshops require attendees to complete a quiz, and once passed, a certificate of completion is issued.
For clients who wish to sign up for an Annual Retainer, we offer most of our services for a significantly reduced fee:
- Annual FinCrime Assurance Review
- 4 hours workshop training (typically 1 workshop per quarter)
- 2 hours expert adhoc advice per month
Hours may be added to the standard retainer, as required.
Remediation projects are unable to be included in an Annual Retainer, due to the nature of the work. This type of project will be priced separately.
Our experienced FinCrime consultants can also provide a full professional opinion for more serious matters, email a response to a question that you need answered quickly, or discuss the matter with you on a call.
Get in touch to discuss how we can help
We're experts in our field
Meet Corinna Venturi, Director of Financial Crime. Corinna has worked in both the financial and professional services industries since 1996, first in front line services and then moving into financial crime prevention in 2007. Corinna joined Cosegic in 2022 having been a consultant since 2017. Prior to that she was the Money Laundering Reporting Officer and Head of Compliance for the UK arm of one of the world’s largest Trust and Corporate Services Providers. Corinna leads our Financial Crime Team and is focussed on supporting our clients by providing them with expert advice, assurance on their systems and controls, remediation and training.
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