Managing A Regulatory Crisis: All Leave Is Cancelled

Your first regulatory crisis

Imagine discovering as a newly appointed Non-Executive Director of a financial services business that the client reviews of high-risk clients have not been undertaken for two years, reporting of suspicious activity has lapsed over several months following the resignation of the MLRO, staff AML training is woefully out of date, the Board delegates all things compliance related to the MLCO with no board reporting. Added to that the regulator has undertaken an on-site examination and discovered all of the above but also concluded that the regulatory consultant used to draft your AML/CFT and PF procedures made fundamental errors leading to systemic weaknesses throughout the business resulting in breaches of the Money Laundering Order and the JFSC's AML/CFT/PF handbook. If that wasn't enough you discover your highest fee earning client has just been arrested for fraud. Supervision refers the case to enforcement and alleged breaches of the