Internal Controls Design & Compliance Controls Design

Effective Internal Controls Design Solutions for financial institutions and regulated businesses, tailored to your regulatory obligations. Risk and Compliance Controls | Operational Controls | Vendor Related Controls | Data Management Controls and more.We develop a full range of internal controls to help financial institutions, financial service providers, AML/CFT reporting entities and other regulated businesses address their risk management and compliance obligations effectively. We tailor our solutions to:

  • Your business goals
  • Products you offer
  • The size of your business
  • The available technology
  • Your risk appetite and risk management framework
  • Your governance structure
  • Client demographics
  • Your countries of operation, their applicable laws, regulations, licensing and compliance requirements.

Our focus areas include establishing controls for:

  • AML/CTF risks
  • Fraud risks
  • Sanctions-related risks
  • Corporate governance risks
  • Data privacy risks
  • Risk management requirements under financial licensing regimes and license conditions
  • Financial market conduct-related risks
  • Resource management risks
  • Operational risks, including but not limited to:
  • Product promotion
  • Customer onboarding
  • Customer communication
  • Transaction monitoring
  • Internal communications
  • Reporting
  • Incident management
  • Third-party risk management
  • Recordkeeping
  • Conflict of interest management

 

Compliance Controls

Our focus areas include, but are not limited to, developing compliance controls to comply with:

  • Financial laws and regulations
  • Financial licensing regimes
  • Anti-money laundering and counter-terrorism financing (AML/CFT) laws and regulations
  • Data management and privacy laws
  • CRS (Common Reporting Standard) and FATCA (Foreign Account Tax Compliance Act)
  • Sanctions laws
  • Other regulated areas

 

Service Coverage

Specialised Internal Controls Design tailored to your specific commercial targets, markets of operation, business requirements, and internal controls audit obligations. Risk and Compliance Controls linked to RMFs, CMFs, CMPs, risk rating methodologies, and other key documents.We design internal controls for the following types of entities:

 

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)

 

Regional Coverage

Our control design solutions are best suited for the following jurisdictions:

Developed Financial Markets 

  • Australia: Internal controls designed to meet the standards of:

 

  • United Kingdom: Internal controls designed to meet the standards of:

 

  • United States: Internal controls designed to meet the standards of:

 

  • Singapore: Internal controls designed to meet the standards of:
  • Financial Services and Markets Act 2022
  • Capital Markets Services Licence, Payment Institution Licence, Digital Banking Licence, and Finance Company Licence (under the Finance Companies Act)
  • MAS AML/CFT guidance, including the CDSA and other relevant laws and regulations

 

  • European Union: Internal controls designed to meet the standards of:
  • European and national financial marketing conduct AML/CFT laws and regulations
  • Local financial licensing regimes

 

  • New Zealand: Internal controls designed to meet the standards of:

 

Offshore Financial Centres: Internal controls designed to get and retain a financial licence or operate an AML/CFT regulated entity in the following countries:

  • Belize:
    Internal controls designed to meet the standards of:
    • International Financial Services Commission Act for Financial Licensing
    • Money Laundering and Terrorism (Prevention) Act
  • British Virgin Islands:
    Internal controls designed to meet the standards of:
    • Securities and Investment Business Act (SIBA), administered by the Financial Services Commission (FSC), for financial licensing
    • Proceeds of Criminal Conduct Act
  • Cayman Islands:
    Internal controls designed to meet the standards of:
    • Monetary Authority Law and related regulations under the Cayman Islands Monetary Authority (CIMA) for financial licensing
    • Proceeds of Crime Act (2020 Revision) and Anti-Money Laundering Regulations (2020 Revision)
  • Jersey:
    Internal controls designed to meet the standards of:
    • Financial Services (Jersey) Law 1998, regulated by the Jersey Financial Services Commission (JFSC), for financial licensing
    • Proceeds of Crime (Jersey) Law
  • Malta:
    Internal controls designed to meet the standards of:
    • Financial Institutions Act, overseen by the Malta Financial Services Authority (MFSA), for financial licensing
    • Prevention of Money Laundering Act (PMLA)
  • Dubai:
    Internal controls designed to meet the standards of:
    • DIFC Regulatory Law No. 1 of 2004, DFSA Conduct of Business Module (COB), DFSA Prudential Rules, and other applicable laws and regulations
    • DIFC and DFSA Standards and Dubai Virtual Assets Regulatory Framework
    • Federal Decree-Law No. (20) of 2018 on AML/CFT
  • Bermuda:
    Internal controls designed to meet the standards of:
    • Investment Business Act 2003, under the Bermuda Monetary Authority (BMA), for financial licensing
    • Proceeds of Crime Act 1997 and Anti-Terrorism (Financial and Other Measures) Act 2004
  • Mauritius:
    Internal controls designed to meet the standards of:
    • Financial Services Act 2007, administered by the Financial Services Commission (FSC), for financial licensing
    • Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA)
  • Seychelles:
    Internal controls designed to meet the standards of:
    • Financial Institutions Act 2004, regulated by the Seychelles Financial Services Authority (FSA), for financial licensing
    • Anti-Money Laundering and Countering the Financing of Terrorism Act 2020
  • Vanuatu:
    Internal controls designed to meet the standards of:

 

Internal Controls Design for Startups and Small Businesses

We design internal controls tailored to the needs of startups and small businesses to help them address compliance obligations and operational risks effectively while maintaining scalability. Key focus areas include:

  • Foundational Controls: Establishing essential controls for areas like customer onboarding, transaction monitoring, and recordkeeping.
  • Scalable Solutions: Developing controls that can adapt as the business grows, ensuring compliance remains manageable.
  • Cost-Effective Implementation: Designing practical controls that balance compliance requirements with resource constraints.

 

Internal Controls Design for Company Groups

For company groups, we create cohesive internal controls that align with group-wide policies while addressing specific risk management requirements of individual entities. Key areas of focus include:

  • Unified Control Frameworks: Developing group-wide control structures that promote consistency across all subsidiaries.
  • Intercompany Risk Mitigation: Designing controls to manage risks related to shared services, intercompany transactions, and centralised functions.
  • Integrated Compliance Mechanisms: Aligning controls with group governance frameworks for streamlined compliance.
  • Technology-Enabled: We help you leverage technology tools to automate routine compliance tasks, freeing up your team to focus on core business activities.

 

Internal Controls Design for High-Risk Corporates

For high-risk corporates, we design robust controls to address heightened regulatory scrutiny and complex operational risks. Our approach includes:

  • Advanced Risk Mitigation Controls: Crafting controls to manage high-risk areas such as fraud, sanctions compliance, and data privacy.
  • Customised Design: Tailoring controls to fit the specific risks and regulatory circumstances to keep your business going despite heightened scrutiny
  • Ongoing Adaptability: Ensuring controls are dynamic and capable of evolving with regulatory changes and emerging risks.

 

Examples of Controls We Can Design

The following list is not exhaustive. Our services cover designing internal controls in the following key areas:

  • Regulatory Compliance & Licensing Controls: Covering compliance management, internal and compliance controls for specific licensing requirements, liquidity management, capital adequacy, financial auditing, regulated counterparty engagement, cross-border application of regulations, automation in trading regulation, and more.
  • Operational Oversight Controls: Covering outsourcing oversight, risk management, governance arrangements, incident escalation and management (including STRs, SARs, and SMRs), senior management accountability, operational resilience, and more.
  • Market Integrity & Transparency Controls: Covering market conduct standards, fair dealing principles, conduct and disclosure standards, service provision standards, product governance, client asset protection, and dispute resolution mechanisms.
  • Resource Management Controls: Covering resource adequacy, professional competence, and the competence of advisors and representatives.
  • Reporting Controls: Covering transactional reporting (including PTRs, TTRs, and specific obligations as part of financial licence-holding requirements), regulatory reporting, financial reporting and assurance, internal reporting, and record-keeping.
  • Product and Service Management Controls: Covering product suitability, product lifecycle oversight, data protection and privacy, customer due diligence (CDD), enhanced customer due diligence (EDD), politically exposed persons (PEP) screening, and sanctions screening.
  • Fraud Detection and Management Controls: Designed to detect and manage fraudulent activities, including transaction monitoring, fraud risk assessments, internal fraud prevention mechanisms, and controls for detecting unusual patterns or customer behaviour.
  • Transactional Controls: Covering ongoing due diligence, capturing large, complex, and unusual transactions and patterns, electronic trading risk requirements, fraud prevention, position limits, position accountability, and more.
  • CRS and FATCA Controls: Covering client identification, documentation of tax residency, due diligence for foreign account holders, reporting of relevant accounts to tax authorities, and compliance with global tax transparency standards.

 

Internal Controls Design in Context

We offer the following related solutions for different lines of defence to supplement this service:

Compliance Risk Management

  • Compliance Advisory Service to help your risk and compliance teams and management with various aspects of regulatory compliance. Visit our Compliance Advisory page for more information.
  • Key compliance documents: We draft, review, implement and enhance compliance management frameworks, compliance programs and plans, compliance calendars and checklists, and other relevant documents.
  • 2nd Line Compliance Management: Full-scale regulatory compliance function leadership. Visit our Regulatory Compliance Management page for more information.
  • Compliance Training Solutions: Effective and role-specific training to ensure staff are equipped to manage compliance obligations effectively. Visit our Compliance Training 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.
  • Remediation Services: Targeted support to address identified compliance gaps and align with regulatory standards. Visit our Remediation Services page for more information.

 

AML/CFT Compliance

 

3rd Line Compliance Assurance

3rd Line Compliance Assurance Solutions: Compliance Assurance Program development and implementation, independent compliance assurance testing, with effective reporting. Visit our Compliance Assurance Solutions page for more information.