Compliance Remediation Solutions | Compliance Breach Remediation Plan Management | Regulator Relationship Management | Compliance Enhancement

We offer a complete set of regulatory compliance remediation solutions to licensed financial institutions, financial service providers, reporting entities subject to anti-money laundering and counter-terrorist financing laws and regulations, and other regulated entities to address and rectify compliance issues, support compliance enhancement, and restore regulator relationships. Our focus areas include:

  • Root Cause Analysis
  • Compliance Remediation Plan Development
  • Compliance Process and Controls Enhancement
  • Addressing Internal Controls Failure
  • Policies and Procedures Enhancement
  • Incident Response Remediation
  • AML/CFT Breaches Remediation
  • Financial Licence Restriction Removal
  • Regulatory Action Plan Implementation
  • Post-Implementation Control Testing
  • Regulator Relationship Management

 

Service Coverage

We offer remediation solutions to:

Financial Institutions and Regulated Entities

  • Investment bankers, investment firms, and fund managers, including MIS (Managed Investment Schemes) and DIMS (Discretionary Investment Management Services)
  • Brokers, including forex brokers and derivatives platforms
  • Currency exchange providers, e-money issuers, money remitters, and money transmitters
  • Non-bank lenders, including consumer credit providers, credit unions, corporate finance providers, building societies, savings and loan associations, and finance companies
  • Neo-banks
  • Derivatives issuers
  • Investment advisers and wealth managers, including financial planning specialists
  • Custodians and licensed trustees, including custodial or depository service providers
  • P2P lending platforms and crowdfunding services
  • Insurance providers, including life and maritime insurance providers
  • Online casinos and gambling outlets
  • Fintech companies
  • Payment gateway providers

 

Public and Private Organisations

  • Publicly listed companies
  • Private companies
  • Family-owned businesses
  • Non-profit organisations

 

Designated Non-Financial Businesses and Professions (DNFBPs)

  • Accountants, lawyers, and auditors regulated under AML/CFT obligations
  • Real estate businesses
  • Trust and company service providers (TCSPs)

 

Our compliance breach remediation solutions cover non-compliance in the following areas:

  • Financial laws and regulations
  • Financial licensing regimes
  • Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) laws and regulations
  • Data management and privacy laws
  • Common Reporting Standard (CRS) and Foreign Account Tax Compliance Act (FATCA)
  • Sanctions laws

 

Regional Coverage

We offer compliance remediation solutions for business that operate under:

  • Australian compliance regime, including remediating non-compliance with the Corporations Act, AFSL licensing regime, AML/CTF Act 2006, and APRA standards and codes of practice.
  • United Kingdom compliance regime, including remediating non-compliance with FCA’s authorisation regime, FSMA 2000, Money Laundering, Terrorist Financing and Transfer of Funds (Information Powers) Act 2017, SAMLA 2018, POCA 2002, and PRA rules.
  • United States compliance regime, including remediating non-compliance with:
  • SEC regulations for securities and markets
  • FINRA provisions for brokerage firms and broker-dealers
  • CFTC regulations for derivatives markets
  • CFPB enforcement regime for consumer protection
  • NCUA regulations for credit unions
  • Anti-Money Laundering Act of 2020
  • Bank Secrecy Act
  • Singapore compliance regime, including remediating non-compliance with the Financial Services and Markets Act 2022, requirements of the Capital Markets Services Licence, Payment Institution Licence, Digital Banking Licence, Finance Company Licence under the Finance Companies Act, and Singaporean AML compliance, including the CDSA.
  • European Union compliance regime, including remediating non-compliance with European and national financial market conduct laws, AML/CFT laws, and local financial licensing regimes.
  • New Zealand compliance regime, including remediating non-compliance with the Financial Markets Conduct Act and applicable regulations, licence conditions set out by the FMA, FSPR requirements, and AML/CFT Act 2009.
  • Other jurisdictions, including regulatory remediation in the following prominent formation centres:
    o Belize
    o British Virgin Islands
    o Cayman Islands
    o Dubai
    o Bermuda
    o Panama
    o Jersey
    o Malta
    o Mauritius
    o Seychelles
    o Vanuatu

 

Root Cause Analysis

We will conduct a thorough investigation to identify the root cause of the breach, such as human error or system vulnerabilities, to enhance remediation effectiveness and prevent similar incidents.

 

Compliance Remediation Plan Development

Effective Compliance Remediation Planning: Following the root cause analysis, we will help your team draft a detailed compliance remediation plan. This plan will serve as a roadmap to enhance compliance and address the identified causes to facilitate breach remediation. We tailor compliance remediation plans to:

  • Your business goals
  • Your budget
  • The severity of the breach
  • The expected remediation timeline
  • The size of your business
  • The available resources and technology
  • Your risk appetite
  • Your governance structure
  • Stakeholder expectations
  • Other applicable risk and compliance obligations

 

Clear Reporting: We will communicate a clear remediation action plan proposal to relevant stakeholders, including your risk and compliance team, senior management, and legal teams, outlining the identified findings, proposed solutions, required resources, and timeline for effective remediation.

 

 

Regulatory Action Plan Implementation

We can act as dedicated remediation project managers to oversee the implementation process and ensure all tasks are completed on time. We assist businesses with the remediation plan rollout by:

  • Collaborating with Business Units: Working closely with your business units to implement the necessary enhancements identified during the remediation process.
  • Providing Progress Reports: Engaging with management to report on the implementation progress and address accompanying issues.
  • Resource Allocation Planning: Identifying and allocating the required resources (human, technological, or financial) to facilitate the remediation process effectively
  • Stakeholder Communication: Establishing clear communication channels to keep stakeholders informed of progress, challenges, and key milestones throughout the remediation process.
  • Regulatory Liaison Support: Acting as a point of contact for regulators during the implementation phase, providing updates and addressing queries as needed.
  • Training and Awareness: Delivering tailored training sessions to ensure staff understand the changes and their roles in maintaining compliance moving forward.
  • Ongoing Risk Assessment Integration: Ensuring that remediation efforts are integrated into your broader risk management framework to proactively identify and mitigate future risks.

 

Post-Implementation Control Testing

Verifying the effectiveness of your regulatory remediation efforts is crucial. We can assist with post-implementation control testing and attestation, focusing on:

  • Compliance Testing and Verification: Conducting detailed post-implementation testing to verify the effectiveness of implemented remediation measures.
  • Executive Attestation Support: Assisting senior executives in preparing required attestations for regulators and other stakeholders. This includes confirming that all necessary remedial actions have been undertaken and that adequate compliance measures are in place, supported by comprehensive documentation and evidence.
  • Post-Remediation Ongoing Monitoring: Establishing ongoing monitoring processes to identify and address any potential issues that may arise in future, reducing the risk of recurrence.
  • Feedback Integration: Analysing insights gained during testing to adjust controls and processes as needed for continuous improvement.
  • Stakeholder Communication: Facilitating communication with relevant internal and external stakeholders regarding the testing outcomes and ongoing compliance measures.

 

Regulator Relationship Management

Restoring an effective relationship with your regulator is a critical component of resolving regulatory issues.  Our focus areas include:

  • Regulatory Liaison During and After the Process: Acting as a dedicated regulatory liaison, serving as the primary point of contact with your regulator.
  • Ongoing Updates: Facilitating clear and consistent communication throughout the remediation process to keep your regulator informed of progress and challenges. Updates include detailed milestones, actions taken to address identified issues, and adjustments made to the remediation plan.
  • Presentation Preparation: Assisting in the creation of clear and concise presentations for your regulator to effectively communicate your remediation plan, progress, and steps taken to prevent similar issues in the future.
  • Regulatory Audit Assistance: Preparing all necessary documentation and training your team to effectively respond to auditors’ inquiries.

 

 

Examples of our Compliance Remediation Services

Addressing Internal Controls Failure

Internal control failures are a common cause of compliance breaches. Remediation strategies and regulatory risk management may not achieve desired outcomes if there are insufficient controls in place or if existing internal controls are ineffective.

With extensive expertise in internal control design and testing, we can:

  • Independently review your current compliance controls to assess their effectiveness.
  • Adjust controls to align with your compliance enhancement needs.
  • Develop additional controls tailored to your size, resources, markets of operation, and products.

For more information, you can visit our designated Internal Control Design page and Internal Controls Testing page.

 

AML/CFT Compliance Breach Remediation

We bring over 15 years of experience in anti-money laundering (AML) and counter-terrorism financing (CTF) compliance, including the successful implementation of remediation plans. Our AML/CFT solutions cover:

  • Advising on your remediation steps
  • Leading a comprehensive AML compliance enhancement
  • Helping you maintain your banking relationships
  • Assisting with ongoing AML/CFT management during the remediation process

 

Financial Licence Restriction Removal

A less severe regulatory compliance breach may result in the imposition of restrictions or additional conditions on a financial institution. We help licensed and authorised financial institutions:

  • Comply with the imposed specific conditions
  • Remediate issues that led to their imposition
  • Facilitate their removal

 

Incident Response Remediation

Regulatory compliance breaches are often caused by incorrect actions or delays in responding to incidents by your response team. We focus on resolving your incident response issues by:

  • Reviewing Incident Management Processes: Analysing current processes to identify gaps or inefficiencies that contributed to the breach.
  • Enhancing Incident Response Protocols: Developing or updating protocols to ensure timely and effective responses to future incidents.
  • Training Response Teams: Providing targeted training to equip your team with the skills and knowledge needed to handle incidents in line with regulatory requirements.
  • Implementing Monitoring Mechanisms: Establishing ongoing monitoring systems to detect and mitigate risks early.

 

Compliance Framework Enhancement

Our focus areas include:

  • Procedural Enhancements: We update existing procedures or develop new ones specifically designed to prevent similar compliance breaches from recurring.
  • Operational Workflow Optimisation: We create efficient workflows for critical business operations to ensure ongoing compliance with regulatory requirements.
  • Corporate Governance Enhancements: We support your compliance function and management by establishing clear reporting mechanisms through tailored compliance calendars, checklists, and reports for the board and its delegated committees or functions.
  • Enhanced Training Programs: We develop or revise training programs to ensure employees are equipped to manage compliance matters effectively, integrating breach prevention strategies into training modules.
  • Role-Specific Compliance Training: We deliver targeted training for various business units and functions, including customer support, operations, banking, KYC and AML/CFT teams, risk and compliance departments, and more.

 

Technology Integration

We assist businesses in implementing new risk and compliance management tools as part of the remediation process. Our focus areas for this service include:

  • Needs Assessment: Identifying specific technology requirements based on the breach and your operational needs
  • Compliance Technology Selection: Recommending tools tailored to the specific breach, operational structure, available resources, and compliance obligations
  • Customisation and implementation assistance across the business
  • Testing: Assisting with testing to validate functionality, usability, and integration with your risk management and compliance structures
  • Documentation Streamlining: Updating policies, procedures, workflows, and process maps to accommodate the technology selection

 

 

Compliance Review and Gap Analysis

While self-identification is not an absolution from a warning or a fine, it is still better to find issues and fix them before an external party does. We offer several solutions focusing on regulatory compliance gap identification.

Third Line Compliance Assurance Review

We conduct a detailed analysis of your compliance status. Our focus areas include, but are not limited to:

 

Internal AML/CFT Compliance Review

This is a confidential review to identify and address gaps and prepare you for an external audit or AML/CFT supervisors’ review. Visit our Internal AML/CFT Compliance Review page for more information.

 

Avoiding Regulatory Compliance Breaches Recurrence

We have a number of solutions to help you prevent compliance breach recurrence:

Regulatory Compliance Risk Management

  • Compliance Advisory Service to assist your risk and compliance teams and management with various aspects of regulatory compliance. Visit our Compliance Advisory page for more information.
  • Second Line Compliance Management: Full-scale regulatory compliance function leadership. Visit our Regulatory Compliance Management page for more information.
  • Vendor Risk Management: A full range of services to help with your compliance obligations related to outsourcing under different laws and regulations. Visit our Vendor Risk Management page for more information.
  • Fraud prevention solutions: Helping your business identify fraud activities and manage fraud risks. Visit our Fraud Prevention page for more information.
  • Customer onboarding solutions: Helping you streamline customer onboarding while remaining compliant with applicable laws and regulations. Visit our Customer Onboarding Page for more information.

AML/CFT Compliance Enhancement