FINTRAIL experts support a banking-as-a-services (BaaS) provider to eliminate weaknesses across their anti-financial crime controls
Context
BaaS is a rapidly growing market segment enabled by digital transformation and open banking, but one with unique financial crime risks and requirements. FINTRAIL assisted a UK and EU-based BaaS provider with addressing process inefficiencies and weaknesses in its control framework, and communication challenges with external agents.
Solution
We reviewed our client’s internal financial crime operations, and assessed and suggested recommendations for enhancing the programmes and operations of its agents:
Operating model review: a review of specific operational areas including onboarding, screening, and transaction monitoring, and recommendations of achievable action points to help the firm make improvements and gain efficiencies in each area.
Onboarding retained support: providing financial crime expertise to assist with the onboarding of agents in line with UK requirements, conducting risk assessments at prospecting; a full review of agents’ financial crime framework; initial assurance and implementation support to close any gaps before launch; ongoing assurance; and agent training.
Customer risk rating: development of a new customer risk rating methodology, by reviewing different agent products to establish mandatory minimum standards. This included development, testing and refinement of both retail and corporate customer risk rating methodologies.
Deep-dive assurance reviews: annual assurance health check report identifying any new risks or significant programme changes against BaaS requirements.
Retained advisory services: offering ongoing advice on specific regulatory issues, providing regulatory updates, and supporting horizon scanning.
Training: ad-hoc transaction monitoring and PEPs and sanctions training for internal teams.