Investigations & remediation

Investigation & remediation

Close scrutiny of financial records can reveal organised criminal activity. The link between the origins of a payment, the people involved, when the money is received and where it is deposited can provide information about and proof of money laundering and/or terrorist financing.

Our services

We have highly specialised skills and experience in understanding financial payment flows, corporate structures, banking systems and money laundering schemes, as well as using analytical software.

We work with financial institutions, both large and small, on financial crime investigations involving highly complex, cross-border criminal activity by taking a 'follow the money' approach. Often these investigations are multi-jurisdictional and involve high volumes of forensic data to be collected and reviewed.

We provide independent expertise in conducting highly sensitive bribery and corruption investigations using our knowledge of worldwide anti-corruption instruments such as the UK Bribery Act and the US Foreign Corrupt Practices Act.

We help our clients to implement best practice to detect money laundering and financial crime before it occurs.

Forensic investigations

Conduct deep forensic investigations into suspicious payments and potential regulatory breaches.
Investigate transactions and identify weaknesses in bribery and corruption compliance and risk management infrastructure.
Full forensic investigations relating to bribery and corruption incidents.
Conduct detailed document reviews and fact-finding interviews.
Recover and extract large-volumes of forensic data from data lakes and archive systems.
Track payments through the global banking system to provide evidence of criminality.
Provide support to law firms as Subject Matter Experts (SMEs) as part of joint Skilled Person teams.

Look-back reviews

Work closely with in-house legal teams and external counsel as well as compliance teams to manage look-back projects.
Extract comprehensive payment information from data lakes and archive systems.
Conduct deep forensic reviews and establish definitively if a payment was ultimately paid by looking at the individual legs of a payment.
Assemble coherent narratives as to why, where, when and how a payment was made.
Design, build and operate Voluntary Self Disclosure (VSD) processes for investigating and reporting on breaches.
Produce comprehensive self-disclosure packs for submission to regulators.
Testify at US Department of Justice (DoJ) hearings.

Regulatory response & remediation

Design and deliver remediation programmes to address regulatory feedback.
Remediate controls gaps in payment environments.
Improve the quality of sanctions alerts resulting from enforcement actions.
Implement post-regulatory action requirements, such as remediating non-compliant KYC and transaction files.
Evidence that obligations to use MT202COVs, FATF R.16 and FATCA compliance are being met.
Identify exceptions and deviations from SWIFT standards.
Provide independent assurance around agreed remediation programmes.
Provide advice and assistance to firms subject to an FCA s166 review.

A common thread for solving most serious and organised crime, almost irrespective of its nature, is to follow the money.

Steve Smart

FCA