AML/CTF/CPF
As governments and international organisations continue to focus on the fight against economic crime, regulators expect firms to ensure that their programmes can deliver effective and sustainable systems and controls to address the evolving threat landscape.
Adopting a culture of compliance:
Regulated firms are increasingly faced with criminal actors who adopt sophisticated strategies mixing emerging technologies and old tactics to avoid detection. Consequently, they must adapt their approach by:
- Discarding a tick-box approach to compliance;
- Understanding and complying with increasingly complex legal and regulatory obligations across multiple jurisdictions;
- Embracing and nourishing a culture of compliance across their organization;
- Educating all colleagues to the challenge and opportunity as well as their individual roles to manage the threats.
Firms who regularly review and invest in their financial crime programmes benefit from:
- Increasing the effectiveness and efficiency of their systems and controls, and in turn demonstrable compliance with their legal and regulatory obligations;
- Enhancing the overall customers’ experience and ensuring risk-based and proportionate friction at onboarding and throughout the client relationship;
- Reducing their exposure to financial loss through criminal activity;
- Reducing the likelihood of enforcement action, costly fines and associated remediation work;
- Protecting their reputation, market value and maintaining their customers’ trust;
- Reducing the cost of compliance and improving their bottom line.
How Plenitude can help:
Plenitude can help you to implement an effective, proportionate and sustainable Anti-Money Laundering (AML) / Counter-Terrorist Financing (CTF) / Counter-Proliferation Financing (CPF) framework and evidence a robust ‘risk-based approach’ to your financial crime programme. All too often, tactical financial crime controls are implemented in response to new business initiatives or regulatory pressure without a full assessment and understanding of intended and unintended consequences. This can fail to address the root cause issues or increase the costs of compliance.
Adopting a risk-based and proportionate approach to financial crime compliance is critical to delivering an effective and sustainable programme. In turn, firms can efficiently deploy their resources, allowing them to remain agile in meeting financial crime threats when and where they arise.
Our team of experts can support your firm with the following services:
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Independent Assessment:
undertaking a proportionate assessment of your controls to manage compliance in readiness for regulatory reviews or to take proactive action
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Regulatory Reviews:
supporting firms through S166 Reviews (firm-side) or conducting S166 Reviews on behalf of the FCA on the basis Plenitude is appointed to the Skilled Person panel for Lot E: Financial Crime. Guiding firms through the remediation process linked to enforcement action or regulatory review
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Risk Assessment
design and conduct a comprehensive risk assessment to assess your AML / CTF / CFP risk
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Financial Crime Framework:
assess and enhance AML-related policies, standards and procedures
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Programme Transformation
designing, implementing and leading transformation programmes
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Tech and Data Services - Health Check / Effectiveness Testing and Transaction Monitoring optimisation:
end-to-end validation of monitoring platforms with regard to identifying gaps in risk coverage and options for improving efficiency and effectiveness. Scenario assessments (condition and threshold), scenario testing, threshold tuning, scenario generation and effectiveness testing
The social harms of money laundering
Financial institutions play a fundamental role in safeguarding the integrity of the financial system. Aside from mitigating the severe financial and reputational risks that they can face if they fail to comply, firms also have a social and ethical obligation to contribute to the fight against money laundering. Customers, employees, shareholders and suppliers expect financial institutions to meet their obligations in order to combat the social harm caused by financial crime. Far from being a victimless crime, money laundering has a direct link to:
- Human trafficking (a £185 billion global industry, where 1/3 of victims are children);
- Drugs trafficking (reportedly worth around £650 billion a year);
- Illegal arms dealing (worth an estimated £10 billion a year).
Our Services
Our capabilities address the entire spectrum of financial crime risks and, as a full-service provider, we can meet all of our clients’ needs in order to deliver a truly integrated consulting service. We can assist with a wide range of needs, including independent assessments, policy and standards enhancement, risk assessments, specialist tech and data support, and remediation and transformation program design and execution. No matter what the requirement, we are here to help.
Discover more about our services and see why our integrity, passion and delivery excellence have been praised by so many clients.
Data Analytics Services
Data quality, siloed systems, and the ever-evolving tactics of criminals make effective data analysis a constant battle. Firms need to break down these silos to get a holistic view of customer activity and identify hidden patterns that might indicate a financial crime threat.
Our specialists
Daniel Keay
Director
Jesal Punjani
Managing Director, Co-Head of Advisory & Transformation Service
Zubin Lee Kasture
Managing Director, Co-Head of Advisory & Transformation Service
Briony Rippington-Bond
Chief of Staff
Munir Merchant
Managing Director, Head of Tech Advisory
Manuel Fajardo
Director, Head of Digital Assets
Alejandro Escolar
Director, Head of Screening
Edward So
Director, Head of Transaction Monitoring
Tom McKay
Head of Data Analytics
Alex Brennan
Senior Manager
Alex Statham
Senior Manager
Christopher Duffy
Senior Manager
Graeme Ford
Senior Manager
Paul Mclear
Senior Manager
Dovile Morkunaite
Manager
Fayad Heibi
Manager
Haseeb Ahmad
Manager
Liam Hurrell
Manager
Sean Bresnahan
Manager
Simon Hancock
Manager
James Williams
KYC QC Lead
Phillip Kelly
KYC QC Lead
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