fscom was engaged by a multinational investment management firm, which was in the early stages of partaking in a funding round for an industry leading money transmission firm. As part of this project, fscom was required to conduct a full-scope compliance audit and, as such, undertake a key role in the firm’s wider due diligence process.
Project background and objectives
fscom conducted a full-scope compliance audit of the firm’s business processes, documented policies, personnel and controls, in order to compare its existing compliance procedures against the regulatory obligations to which it is subject. This included all obligations relating to applicable anti-money laundering and counter terrorist financing regulations and legislation, including domestic and international sanctions regimes, as well as all regulatory compliance obligations relating to applicable to a global money transmission firm.
fscom undertook an initial off-site document review, before conducting a period of on-site testing to test all components of the firm’s AML/CTF framework; this included walkthroughs of all procedures in practice, testing of CDD files held on customers and interviews with key personnel (in order to gauge the wider culture of compliance in place at the firm).
On completion of the testing component, initial results were presented to representatives of the money transmission firm, in order to confirm findings and allow for management response.
After this point, a full audit report was presented to the investment firm, in order to demonstrate that all expected standard have been met; this contained all findings and issues as identified, the relevant legislation or industry guidance that each finding breaches, an objective risk rating and a recommendation how each issues as identified may be remediated.
With fscom’s assistance, the investing firm completed its due diligence process and participated as fully in the funding round.