SYSC326 provides temporary senior level financial crime resource and skills on a project-oriented basis. The short-term provision of project support by an experienced manager to aid organisational transition or change.
Commercial organisations typically engage Interim Management for a specific project, or when a need is identified for an experienced practitioner to fill a temporary skills gap in a management team.
We have supported clients to fill temporary gaps in senior financial crime prevention roles, typically where there has been a sudden change in in-house capability, due to resignation, sickness or dismissal.
SYSC326 supports clients at Group and Regional level, having previously held interim Money Laundering Reporting Officer and Head of Financial Crime roles in FCA regulated firms.
Whether a start-up or established business, a firm may encounter difficulty recruiting to a senior position, possibly due to scarcity of skill-set in the market, an impending merger or acquisition or for other reason(s).
Where recruitment is protracted due to candidate notice period, or an organisational change means the Target Operating Model ('TOM') is not fully defined, temporary SME support can bolster a firm's internal framework capability.
We support clients with TOM build and implementation on financial crime risk. We provide functional support to deliver specific projects. These can be a few weeks duration or much longer in some cases.
Money laundering reporting function (SMF17) - The money laundering reporting function is the function of acting in the capacity of the money laundering reporting officer ('MLRO') of a firm.
FCA (Handbook SUP 10C.3.13R) enables cover to be given for emergencies (NB: If a person will perform the FCA-designated SMF17 role for more than 12 weeks, the firm should seek FCA approval).
The FCA may grant time-limited approval to appoint a candidate on an interim basis while a firm seeks to appoint a permanent candidate.