Compliance and anti-money laundering.
Authorisation is the start, not the finish. A regulated firm's first years are when its habits form, and when the regulator is watching most closely.
Ongoing compliance
Returns and reporting
Preparing and checking the returns a firm owes its regulator, on the regulator's calendar rather than the day before it is due.
Compliance monitoring
A monitoring programme built from the firm's own risks, carried out and reported to the board, with findings that are followed through.
Policies kept current
The documents written for the application, revised as the firm, the rules and the regulator's expectations move.
Notifications and changes
New senior managers, new controllers, new activities, material outsourcing — the changes a regulator must be told about, some of them before they happen.
Regulatory change
What new rules mean for the firm in particular — the supplementary safeguarding regime for payment and e-money firms, the Consumer Duty for firms with retail customers, the UK crypto-asset regime for firms moving into it.
Anti-money laundering
Anti-money laundering is where regulated firms are tested hardest, and where a framework written for an application most often fails to fit the business once it is trading.
Business-wide risk assessment
The firm's actual exposure — customers, products, geographies, delivery channels — assessed and written down, and revisited when any of them change.
Policies, controls and procedures
Customer due diligence, enhanced due diligence, ongoing monitoring, sanctions screening and suspicious activity reporting, sized to the firm rather than copied from a larger one.
Support for the MLRO
A second pair of hands for the money laundering reporting officer: on difficult cases, on the annual report, and on what the regulator will expect to see.
Independent review
A review of the framework against the rules and against how the firm actually operates, with findings the board can act on.
Supervisory registration
Some businesses need to register with an anti-money-laundering supervisor without needing full authorisation. We handle those registrations too.
How it is arranged
Ongoing work is agreed either as a retained engagement with a defined scope, or piece by piece. Either way, the firm's own approved persons remain responsible for its compliance. We support them; we do not replace them.