A law firm had been appointed as a Skilled Person to conduct a Section 166 review of various financial crime processes at an e-payments company. The law firm required support and subject matter expertise to assess the adequacy and robustness of the company’s sanctions monitoring. This included:
SQA Consulting rapidly put together a small team of experienced consultants to deliver this review.
Our Screening Assessment Centre was used to generate a number of test files formed of names from various sanctions lists from global regulators. The test files included over 50 different scenarios including variations of names and fuzzy tests to assess the effectiveness of the screening system. It also included scenarios to test the efficiency of the system by evaluating the number of false positives.
The team reviewed the Company’s documentation covering list management, alert management and investigation, controls and governance, training and communication and Quality Assurance and Oversight.
A range of interviews were conducted across the Company’s Compliance and Financial Crime Operations teams with both senior management and more junior team members such as KYC analysts.
Walkthroughs were conducted to observe key processes and controls such as how sanctions alerts were processed from the initial system alert, through manual alert reviews, escalation, investigation and external reporting.
A sample of alerts were reviewed to determine whether true hits would be identified and handled appropriately.
A report was prepared for inclusion in the Law Firm’s report to the FCA. This included observations and recommendations relating to: