A UK branch of a prominent Middle Eastern bank operating in the wholesale and correspondent banking space. The bank is subject to UK regulatory oversight and provides services to a range of international clients.
Corporate, Wholesale and Investment Banking
Section 166 / Regulatory Programme Management
A UK branch of a prominent Middle Eastern bank operating in the wholesale and correspondent banking space. The bank is subject to UK regulatory oversight and provides services to a range of international clients.
Following a Section 166 Skilled Person Review commissioned by the Financial Conduct Authority (FCA), the client was found to have significant weaknesses across its AML Governance Framework and operational controls. The review highlighted systemic deficiencies in governance oversight, risk ownership, control execution, and the day-to-day effectiveness of AML processes.The bank faced regulatory pressure to rapidly address the findings. It needed a credible partner to lead the design and implementation of a comprehensive remediation programme, ensure ongoing regulatory engagement, and restore confidence at both board and regulator level.
Lysis Group was appointed to lead the end-to-end remediation programme, leveraging its deep expertise in financial crime compliance, operations, and regulatory liaison. Our multidisciplinary team worked closely with the bank’s executive leadership, compliance functions, and external stakeholders to deliver a sustainable and regulator-approved transformation.
Key elements of our approach included:
• Full remediation of the AML Governance Framework, including:
• Clarification and strengthening of roles, responsibilities, and reporting lines
• Revision of policies and procedures in line with UK regulatory expectations
• Development of a robust AML risk assessment and risk appetite framework
• Overhaul of Financial Crime Operations, including:
• Re-design and implementation of client onboarding, KYC refresh, and EDD processes
• Enhancement of transaction monitoring and sanctions screening protocols
• Deployment of a quality assurance framework to ensure consistency and compliance
• Senior Stakeholder Engagement, including:
• Regular presentation of findings, progress, and key risks to the Board and the Audit & Risk Committee
• Close collaboration with the bank’s Head Office to align remediation with group-wide standards
• Regulatory Interface, including:
• Direct engagement with the FCA, providing updates, evidence of progress, and validation of remediation activities
• Coordination of all formal submissions and responses to regulatory queries
• Successful closure of the Section 166 remediation programme, with the FCA acknowledging that key failings had been addressed and controls materially strengthened
• Significant uplift in the bank’s AML governance and operational maturity, aligning with UK regulatory expectations and industry best practices
• Re-established trust with the FCA and internal stakeholders, with clear governance structures, risk ownership, and operational competence
• Improved reporting and board-level oversight, creating transparency and accountability across the financial crime compliance function
• A strong foundation laid for continued growth in the UK market, with reduced regulatory risk and increased operational resilience
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