Selected Advisory Case Studies

• Met monthly with the MLRO. Read the governance packs, transaction monitoring MI, investigations updates, sanctions reporting, CDD quality data, remediation progress and financial crime training metrics before each meeting.
• Attended the financial crime committee. Listened to where the discussion landed and where it skipped. Challenged numbers that looked tidy when the underlying picture was not.
• Tracked emerging supervisory expectations and new typologies through the year so the report reflected the direction of travel rather than last year's rulebook.
• Drafted the MLRO report section by section with the MLRO. Tested every assertion against the evidence. Rewrote the parts that read like description rather than judgement. Prepared the supporting pack for the Board.
• Walked the MLRO through the report ahead of the Board meeting and prepared the likely questions from non-executive directors.

• Six MLRO reports delivered on time across six successive years.
• Each report named the financial crime priorities for the year ahead with the evidence sitting behind them.
• Reports stood up to challenge from non-executive directors and from supervisors when tested.
• Board discussion moved from receiving the report to interrogating the priorities and resourcing decisions inside it.

One lesson from this engagement was that the MLRO report becomes a different document the moment it is written for a Board that will challenge it, rather than for a Board that will receive it.

• Established the governance arrangements for the migration. Agreed decision rights with the MLRO, the Head of Compliance and the business sponsor. Chaired the operational steering meeting through the programme.
• Reviewed the screening output as it ran. Sat with the operations team on the higher-risk customer cohorts. Worked through the files where the inherited rating did not match the firm's own methodology.
• Reviewed the programme MI weekly. Escalated the cases where source of wealth, beneficial ownership or PEP status had to be revisited. Approved the exit decisions where the customer no longer fit the acquiring firm's risk appetite.
• Prepared and presented the phase-end updates into the financial crime committee and the Board, including the harder cases and the rationale for each exit.

• Customer book migrated inside the eight-month window with no slippage to the regulator-facing deadline.
• Higher-risk cases documented to a standard the MLRO signed off and could defend.
• Exit decisions on inherited customers evidenced individually, with rationale on file.
• Board left with a written record of how each material decision was made and by whom.

One lesson from this engagement was that an acquired customer book reveals more about the acquiring firm's risk appetite than any policy document does, because it forces decisions that the policy had only described in the abstract.

• Established the governance for the programme. Agreed decision rights and escalation routes with the MLRO and the Head of Compliance. Chaired the weekly programme governance meeting.
• Sampled completed customer files. Identified the recurring quality issues. Fed the findings back into the reviewer guidance and tightened the file-closure standard before further files were closed.
• Acted as the point of reference for complex implementation questions. Approved the escalated decisions where reviewers were uncertain. Worked through the higher-risk customer cohorts directly with the team leads.
• Rewrote the management information so it surfaced quality and risk rather than activity. Reviewed governance reporting before it went to the steering committee. Prepared the periodic Board updates on programme progress, risks and key decisions.

• Reviewer decision standard reset within four weeks of the engagement starting.
• QA failure rate on sampled files dropped materially across successive sampling rounds.
• Steering committee reporting moved from throughput numbers to quality, risk and escalations.
• Higher-risk cases worked through with documented decisions the MLRO could defend.
• Board received a clear view of where the programme stood, what was being escalated and what the residual risk looked like.

One lesson from this engagement was that governance meetings became significantly more productive once the management information focused on decisions rather than activity.

• Reviewed the prospective institution's public regulatory record, the relevant supervisory framework in its home jurisdiction, recent enforcement activity and adverse media.
• Worked through the institution's responses to the firm's correspondent and institutional due diligence questionnaire. Tested the answers against publicly available information and the firm's internal intelligence. Followed up directly where the picture was incomplete.
• Assessed beneficial ownership, sanctions exposure, PEP connections and the institution's own financial crime governance, transaction monitoring and SAR record.
• Drafted a balanced recommendation for the MLRO and the business sponsor, setting out the material risks, the mitigants the firm could rely on, and the conditions that would need to sit around the relationship if it proceeded.
• Presented the recommendation to the new business committee and answered the trade-off questions live.

• Eight onboarding decisions taken on the basis of documented assessments rather than relationship pressure.
• Relationships that proceeded did so with conditions stated in writing from the start.
• Relationships that did not proceed had the rationale on file, available if the question was asked later.
• New business committee discussion moved from in-principle approval to a specific debate about mitigants.

One lesson from this engagement was that an institutional onboarding decision is easier to defend later when the conditions attached to the relationship were written down before the relationship started, not after.

• Worked through the regulator's document requests with the MLRO and the Head of Compliance. Agreed which materials belonged in which response and what supporting evidence had to sit behind each statement.
• Read the governance packs, committee minutes, MI, policies and procedures that were being submitted. Identified where the documents had drifted from the operating reality. Rewrote the relevant material with the responsible owner.
• Prepared senior management for the regulator interviews. Walked through the likely lines of questioning and the evidence behind each answer. Sat through the dry runs and gave direct feedback.
• Reviewed every written response before submission for consistency with what had already been provided and with what senior management would say in interview.

• Four supervisory engagements completed without an inconsistency between document submissions and senior management interview testimony.
• Documentation gaps identified internally and remediated before the regulator asked.
• Senior management able to explain the judgements behind the framework rather than read from the policy.
• Written record held together when the regulator tested it in follow-up questions.

One lesson from this engagement was that the most damaging issue in a supervisory engagement is rarely a missing control. It is a gap between what the document says, what the senior manager remembers, and what the operating team actually does.

• Read each AML policy and standard in full alongside the relevant new legislation, supervisory guidance and recognised good practice from the year.
• Sat with the operations, compliance and MLRO teams to identify where the existing documents no longer described how the work was actually being done, and where new regulatory expectations had to be reflected.
• Drafted the proposed amendments with the policy owner. Traced each change through into the supporting procedures and reviewer guidance. Worked with the training team where the change had to land with staff.
• Prepared the policy update for committee approval. Set out what had changed and why. Documented the implementation plan and target dates for the operating teams.

• AML policy library refreshed annually within an agreed window, signed off by the policy committee on each cycle.
• Each material change traced into procedures, reviewer guidance and training material before publication.
• Operating teams briefed on what had changed, not just sent a new document.
• Policy committee had a clear written record of what was changing and why each year.

One lesson from this engagement was that a policy refresh only delivers value when the change reaches the operating team. If it stops at the document, the regulator will find the gap before the firm does.

• Sampled completed SAR cases with the investigations team. Read the supporting documentation, the analyst's rationale and the MLRO's decision. Identified where the record was thinner than the decision required.
• Worked with the investigations team to tighten the case write-up standard, the supporting evidence expected for each decision category, and the threshold for escalation to the MLRO.
• Sat in on MLRO decision discussions on the harder cases. Challenged the basis for the conclusion where the file did not support it. Helped redraft the rationale where the decision was right but the record was not.
• Reviewed the onward reporting to the FIU for consistency with the underlying case file. Reviewed the governance reporting to the financial crime committee on SAR volumes, themes and quality.

• Case write-up standard documented and applied consistently across the investigations team.
• SAR decisions evidenced to a standard the MLRO could explain months after the event.
• Onward reporting to the FIU aligned with the underlying case file.
• Financial crime committee reporting moved from SAR volumes to themes, quality and decision patterns.

One lesson from this engagement was that the SAR record is read by people who were not in the room. If the rationale is not on the file, the decision cannot be defended, even when it was the right one.