SYSC326 provides independent monitoring services to clients on financial crime compliance and SME resource support to third party professionals, who provide compliance monitoring services to their own client portfolio (e.g. via b2b arrangements).
Monitoring may be needed as part of a plea-deal arrangement, Deferred Prosecution Agreement, validation of undertakings, or in response to a regulator's requirement for enhanced scrutiny.
Clients and professional services firms may lack in-house SME capability or bandwidth. Support may be needed to design, implement and monitor financial crime systems and controls.
SYSC326 supports FCA regulated firms to respond to regulatory requirements, aligned to adequacy and effectiveness of anti-money laundering, financial sanctions and anti-bribery controls.
Firms may implement organisational change or remediation projects in response to identified risks; sometimes mobilised voluntarily or in response to enforcement activity.
Firms under an enforcement spot-light can benefit from engaging independent professionals, to monitor/challenge the adoption of and compliance with applicable regulatory requirements.
We are accustomed to providing external challenge when reviewing firms' systems and controls. Reviews consider legal and regulatory drivers, as well as industry good practice.
Regulators, governance forums and non-executive directors increasingly seek an independent and informed view on compliance with financial crime policies, procedures and regulation.
Regulators and other stakeholders/bodies may use findings of independent review to assess the extent to which a firm has adopted and maintained internal monitoring and compliance programs.
We consider the content of policies and procedures, and how a firm ensures (or assesses) effectiveness of their implementation, such as, via internal governance and oversight arrangements.