The client is incorporated in Ireland as an Irish Collective Asset-management Vehicle (ICAV). The client is an American investment fund which specialises in lending large amounts of money to various entities ranging from listed entities to unregulated entities based in the USA.
Investment and Asset Management
Client On-Boarding and AML Managed Services
The client needed a seasoned and specialised financial crime (FC) compliance firm to conduct Anti-Money Laundering (AML) assessments on their entities which the client lends money to.
Lysis assists the client with this requirement under the Irish legislation which is the Criminal Justice (Money Laundering and Terrorist Financing) Act of 2010 because the client is incorporated and regulated in Ireland and Ireland forms part of the European Union (EU). The ongoing service offering includes end-to-end Know Your Customer (KYC) operations which is managed by Lysis' secure Cape Town-based operating centre. The set of entities that the client does business with is complex because some of the client's borrowers are unregulated entities which are based in the US with affiliations to high-risk jurisdictions and others are New York Stock Exchange (NYSE) listed entities. As with many listed entities, this client also conducts business with Politically Exposed People (PEP's) who are often associated with listed business entities. However, being identified as a PEP does not necessarily mean that they are involved with illicit activities but, as part of the AML framework requirements, conducting enhanced due diligence is required for high-risk entities.
A UK-based Crypto custodian with a global reach need to meet a regulatory requirement for all personnel to undergo specific training successfully delivered by Lysis.
A crypto asset custodian based in the U.K. with global reach approached Lysis with the request to assist them with the process to obtain registration from the FCA which would enable them to operate in the UK market as a crypto asset business. Due to the holding company’s strong global footprint, part of the FCA requirements for registration included the need for a UK based money laundering reporting officer (MLRO).
Our client wished to ensure that it had all UK regulatory requirements covered by policy, procedures and controls.
