Bright Change co-ordinated the FCA Visit – The visit involved a deep-dive by the FCA to gain an informed understanding of how the Bank applies a risk-based approach to financial crime; and for the FCA to observe & assess compliance across the Tier 1 Bank.

In summary, the FCA wrote to the Bank identifying the scope of its proposed review for Hong Kong, Macau and Dubai, the dates of proposed on-site visits to particular locations/businesses and accompanied by a pre-visit information request.

Project Responsibilities:

• Liaised with the FCA to firm up the key areas of focus for the review during the site visit, along with pre-visit information requests.
• Established a clear governance structure to manage the fast-paced programme and secured Executive Sponsorship to fast track issue management.
• Senior stakeholder management with Group Head of Financial Crime Compliance (FCC) and Lead Business Delivery Manager within Financial Crime Compliance.
• Formulating the plan to ensure sufficient resources were aligned to the request and successfully communicated the importance of the visit to the impacted lines of business.
• Engaged directly with the FCA to clarify information requests & manage expectations for additional documentation requests whilst onsite & post visit.
• Identification of Bank’s personnel to be interviewed by FCA representatives to conduct an end-to-end review of the financial crime risk and control framework.
• Produced Interview Schedules, communications and awareness plans along with detailed guidance notes to ensure interviewees are comfortable with the interview requests.
• Liaised with onsite in country local PMO to track progress vs plan and escalating to steering committee any risks and issues.
• Selection of redacted clients and/or transaction records to be ready for FCA review during an on-site visit.
• Conducted Quality Assurance activity on customer file redaction and ensuring completeness.
• Hosted daily briefing calls with local onsite teams (FCC, Business, PMO and Change Delivery) to capture pre-visit, during the visit and post visit information.

Solution

• Represented the Tier 1 Bank as the single point of contact between the FCA and the impacted jurisdictions: Hong Kong, Dubai, and Macau.
• Uploaded relevant pre-visit and onsite information requests onto Intralinks (document sharing web platform between the Bank and FCA).
• Follow up call with FCA to walk through initial set of findings related to areas of improvement and summary of the visit.
• Produced a BAU Model to manage future visits from the Monitor and ensure the process is embedded within the organisation – Creation of a Monitor Liaison Office (MLO) to manage all future regulatory requests.

Please reach out to Bright Change for a copy of the 15 key questions to ask Compliance before an FCA visit. Note; our FCA visit white paper includes best practices on how best to prepare for an FCA visit.