SYSC326 provides subject matter expertise ('SME') to assist client planning, development and delivery of financial crime projects, whether as part of business-as-usual ('BAU') service delivery, Merger & Acquisition ('M&A') activity, new process implementation, or strategic change to Target Operating Model ('TOM').
Change in legal or regulatory requirements can impact processes deployed in first line operations and how management gains assurance on risk management effectiveness.
Firms must take appropriate measures to prepare for, and during, adoption of new product, practice or technology, in order to mitigate money laundering or terrorist financing risk (Reg. 19.4.(c) MLR 2017).
SYSC326 supports client assessment of, and preparation for, any material change which might be required to internal processes or controls, relevant to financial crime and regulatory compliance.
Due diligence on an M&A target's internal control arrangements aids identification of key risks or issues, or potential strength or weakness in how a target manages financial crime risk.
An acquiring firm’s due diligence should include sample testing of customer identification procedures previously followed by the target, or by a vendor in relation to a portfolio (JMLSG 5.3.21).
We support due diligence planning, testing and/or assessment, to inform client awareness of material regulatory risk or gap, in a target's internal systems and controls framework.
TOM aids certainty and consistency across a business (or operating divisions), of key roles, tools and functionality, as well as providing clarity of responsibility and accountability for financial crime.
TOM expectations should be reflected in the design and implementation of policies, procedures and controls. Senior management provides direction and ensures monitoring to assess conformity.
We are accustomed to working with client and third party Project Managers, when providing financial crime SME support to TOM design, implementation and validation/conformity testing.