Client: Overseas Bank with UK Subsidiary
Scope: Ashlynwood was engaged to undertake a review of the Bank’s KYC process as the MLRO had concerns over the current Bank’s process for identifying High Risk clients during the KYC onboarding process. Assurance was sought over the Bank’s KYC process to avoid regulatory breaches relating to Money Laundering legislation.
Engagement: Ashlynwood undertook a review of the Bank’s KYC process. This included reviewing random samples of KYC cases within various areas of the Bank, evaluating the accuracy of the KYC process and the data stored on the Bank’s CRM system. Our review checked against the minimum required criteria of CDD, EDD and SDD for completeness of information gathered. Samples were tested to ensure the risk ratings assigned were accurate and reflected appropriately including PEP’s. Evidence gathered based on the testing was analysed and evaluated thoroughly to make sure relevant rules and regulations were adhered to. Data control, GDPR governance and accuracy of documentation was included in our review. Additionally, our review also included the ongoing effectiveness of the in-life KYC management and successive periodic reviews.
Outcome: Ashlynwood’s report was submitted to the MLRO and the Board of the Bank with several recommendations over improving the Bank’s KYC process.