EMI/PSP/FIntech

Their ability to provide bank-like services, often coupled with a willingness to service high-risk customers and provide them with flexibility and privacy, makes PSPs and EMIs key disruptors to traditional financial services; however, it also increases the sector’s intrinsic exposure to several financial crime risks, including:

Money laundering, especially in cases with complex ownership of customer risk, such as when distributors and intermediaries are involved
Terrorism financing especially through anonymous cards / purses
Fraud, such as authorised and unauthorised push payment
Sanctions risks

Whether your firm specialises in online money transfers, electronic wallets or prepaid cards, common industry practices such as setting high transaction limits or accepting deposits from unverified parties increase the risks and costs of compliance. Carrying out due diligence on each customer can be a time-consuming and resource-intensive task.

Regardless of a firm’s size, client or product focus, financial crime obligations must be met in every jurisdiction where a firm operates. All too often, this involves notoriously resource-intensive and cost-inefficient systems and controls. Nevertheless, the cost of compliance failures can be unbearable for smaller and newer firms, who often cannot afford to budget for the growing cost of fines and remediations. There is often a misguided perception that regulators need to find evidence of financial crime issues crystallising in order to take action. However, the reality is that the lack of appropriate systems and controls alone can result in a fine or enforcement action.

Our EMI / PSP / FinTech experience

Plenitude has an established track record in assisting EMI / PSP / FinTech clients to proactively assess the effectiveness of their existing Financial Crime Compliance framework, systems and controls, and implementing the required enhancements as part of S166 review or independent assessment, to mitigate the risks highlighted above. We also have supported multiple firms post regulatory review, to advise on the response plan and support the successful implementation of the required enhancements as part of a remediation or transformation programme, including large-scale KYC remediation as part of our Managed Service offering.

We have worked with a variety of institutions in the sector, from innovative FinTech startups to e-money issuers, as well as new firms seeking authorisation.

Our approach, benefits and outcomes we deliver

We understand that all firms’ business activity, customer base and risk appetite will differ. We therefore work closely with our clients to develop a deep understanding of their business and FCC framework in order to develop an effective, proportionate and risk-based approach to financial crime risk management.

Plenitude’s services and capabilities are grounded in our multi-jurisdictional expertise, our proprietary suite of tools and RegTech products, and our deep understanding of sector-specific regulatory obligations and needs. This enables us to deliver the following benefits and outcomes to our clients:

Market-leading advisory, transformation and technical expertise with tech-enabled delivery:

our full-service offering enables us to meet all of our clients’ needs. Our tech-enabled delivery approach leverages our extensive suite of proprietary tools and RegTech products which enables us to accelerate delivery and reduce overall engagement costs.
Regulatory compliance and assurance:

we enable clients to fully understand and meet their regulatory obligations, along with the ability to present robust documentation to demonstrate their conformance with regulatory requirements.
Enhanced efficiency, effectiveness and cost reduction:

our tech advisory, data analytics services and RegTech products enhance efficiency, optimise detection accuracy, streamline workflows and reduce false positives, leading to improved effectiveness and significant cost savings.
Access to cutting-edge technology and future-proofed compliance:

we enable our clients to stay ahead of evolving regulations and criminal tactics by optimising current systems and controls, deploying the latest AI-powered technology and data analytics services.
Compliance transformation: 

we partner with clients to transform their entire compliance function, fostering a culture of data-driven decision-making and continuous improvement.

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.

Advisory & Transformation

Clients typically engage us when they have been subject to regulatory feedback, are expecting a visit from the regulator, or have concerns and want to take proactive action. Regardless of the situation, we can help.

S166 Skilled Person Services

Under the Financial Services and Markets Act 2000 (FSMA), the FCA’s Section 166 review is an independent review by a third party (a ‘skilled person’) about aspects of a regulated firm’s activities where the FCA has concerns or requires further analysis.

Fraud Practice

Global regulatory shifts are compelling financial organisations to prioritise fraud prevention more than ever, and rising fraud complexity highlights the critical role of operational teams as the first line of defence.

Digital Assets Practice

In slightly more than a decade, the digital assets industry has skyrocketed to a market cap of over 2 trillion USD, bringing innovations poised to revolutionise monetary systems, financial services and beyond.

Technology Advisory Services

Regulated firms face a constant battle against financial crime, and technology plays a crucial role in this fight. However, leveraging technology and keeping up with innovation comes with its own set of challenges.

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.

KYC Managed Service

The regulatory landscape continues to evolve placing increased regulatory pressure and demand on institutions to meet their KYC/CDD compliance obligations, often at significant cost.

RegTech Products

Our RegTech subscription products enable our clients to manage financial crime obligations, country and client risk more effectively while reducing internal risks, costs and resource demands.