Gap Analysis in Response to 21 May 2021 FCA Dear CEO Letter (Retail Banks)

The FCA’s May 2021 “Dear CEO” letter to retail banks requires a gap analysis to be carried out against a number of Financial Crime areas where the FCA has noted common weaknesses.

Banks had until 17 September 2021 to complete the gap analysis. The areas covered should have included:

  • Governance and Oversight
  • Risk Assessments (Business Wide and Customer)
  • Due Diligence
  • Transaction Monitoring
  • Suspicious Activity Reporting

We can assist banks still working to complete the required gap analysis either to complete the analysis (where internal resources are not available), or providing a framework to assist an internal team requiring guidance to get the work done efficiently.

Where the gap analysis reveals that remediation work is required, we can assist banks to prepare a robust remediation plan for presentation to the FCA. This proactive approach to addressing gaps will improve the regulator’s confidence in ability of the bank’s management to deal with any gaps without the need for further intervention (e.g. a Skilled Person Report).

If you would like to know more, please use our general enquiry form and mention “Dear CEO gap analysis”.

Reviews of the Financial Crime Framework for MSBs and PSPs/EMIs

Increasingly banks providing services to MSB and PSP/EMI clients are requiring as part of their onboarding and periodic review due diligence processes an independent review of the client’s financial crime framework.

We can provide the required independent reviews based on a scope of work designed to meet the bank’s requirements cost effectively.

These reviews can take the form of agreed upon procedures (minimising cost) or review and recommend (providing additional advice and insight for the MSB or PSP/EMI).

If you would like to know more, please use our general enquiry form and mention either “MSB FC review” or “PSP FC review”.

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