S166 Remediation
Implemented a new IT system and created new policies on PEP’s, CTF, Fraud, Organised Crime and Anti-Money Laundering.
UK Based Payment Provider
The Project
Brighter Consultancy Group successfully secured exclusivity to help one of the largest payment providers in the UK, after the Financial Conduct Authority (FCA) suspended the company for weaknesses related to the its anti-money laundering process.
Our client is a very popular fintech payment processor based in the UK and held in excess of £130 million in customer funds with the functionality to process cross country payments in various types of currencies.
We were instructed to build a new KYC framework, following an FCA S166 mandate to cease trading. The S166 was served due to a number of weaknesses in AML controls, systems and processes. Customer accounts were frozen and the clients ability to process, withdraw and transfer funds was completely restricted.
The Solution
Brighter deployed a team of financial crime SME’s to immediately remediate over 60,000 customers. Our Head of Financial Crime designed and implemented a new KYC Framework and created new policy documents, processes and procedures.
Brighter designed and implemented a new IT system (including a revised App with secure bio-metric verification) and invited customers to re-register their details. We created a brand SAR platform with a clear line of escalation and our financial crime team created new policies on PEP’s, CTF, Fraud, Organised Crime and Anti-Money Laundering.
We recruited three teams across client screening, Transaction monitoring and quality assurance and implemented a risk rating methodology to help identify Countries and customers that present higher risk.
The Results
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Brighter successfully remediated the S166 and worked closely with the FCA to ensure that our client and its customers were able to return to business as usual.
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We created a multi-lingual customer support team that was specifically tasked with dealing with customer complaints and queries.
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Brighter recruited a new permanent SMF17 for the business to ensure knowledge transfer, best practice and cultural change from the top down.
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Brighter Consultancy Group has been retained by the client across a number of area and we lead Steer Committee meetings, forums and workshops to provider strategic oversight and guidance throughout the organisation from Board Level to customer services.