Background
Our client is an established regulated business which has enjoyed the benefits of a robust growth story. The Company’s business model is to offer a frictionless onboarding solution for customers who need access to financial products and services. The model heavily relied on post-onboarding monitoring activity to manage financial crime obligations.
Challenge
This model possesses significant downstream risk in the form of potential financial crime reporting obligations, with a high incidence of cases being referred to the company’s financial crime team for possible escalation to the National Crime Agency (“NCA”).
Solution
We were engaged in deploying one of our industry experts to conduct a regulatory health check to examine ways of reducing the high volume of cases referred to the company’s financial crime function.
Our review revealed that, while the policies were broadly fit for purpose, a misreporting of the age profile of cases led to potential concerns that vulnerable customers may be affected by the delays in dealing with the reports being received.
This resulted in us developing a project plan to eliminate all exceptional cases within a tight customer deadline. The program that was overseen and governed by Dukebridge’s senior SME.
“Our review revealed that, while the policies were broadly fit for purpose, a misreporting of the age profile of cases led to potential concerns that vulnerable customers may be affected…”
Outcome
Our support activities included deploying a team of skilled individuals to support the existing team in clearing all outstanding cases, establishing a process for the efficient and timely submission of SARs to the NCA and the prompt return of funds to vulnerable customers who may have been the victims of financial crime.
We were able to assist our client with eliminating the outstanding cases within one month, thereby eliminating significant regulatory exposure and, simultaneously, through sensitive and appropriate dialogue with the FCA, helping our client avoid regulatory censure.
