Our client, a leading UK bank, had received an unfavourable external review of its Anti-Money Laundering (AML) framework which resulted in a section 166 in the UK. Due to a number of factors the initial response to the review had not landed well leading to:
• Limited visibility of the issues at senior levels;
• Lack of understanding at the top table of the potential impact of the issues;
• Challenges in getting investment in the right areas due to poor coordination;
• Low regulator confidence in the bank’s ability to resolve issues due to a lack of historic delivery;
• Inconsistent reporting to internal and external stakeholders; and
• No macro plan which could be used by executives to track and drive progress.