An international wholesale bank’s London capital markets business was running a second-line KYC lookback and remediation. Files already through remediation still needed independent quality assurance. Higher-risk customers needed enhanced due diligence that would meet MLRO and Head of AML and Sanctions scrutiny.
GRT fielded a financial crime specialist into the second line of defence. Working to the MLRO and Head of AML and Sanctions, we quality-assured remediated KYC files and completed enhanced due diligence covering PEPs, sanctions, adverse media, customer risk assessment, source of wealth and source of funds, and first-line risk acceptance. The assignment was extended so the same GRT resource stayed with the lookback through close-out.
GRT delivered financial crime resource inside the bank’s own second line, rather than handing a half-finished file stack to a new team. Where the client needs more capacity, we staff in the same way: specialists who join their team, or a GRT team that runs a defined slice of the programme.
From a lookback file mountain that still fails second-line scrutiny, to quality-assured KYC and EDD packs ready for MLRO and Head of AML and Sanctions review.
Illustrative of GRT’s second-line delivery model: capacity that embeds with the MLRO / Head of AML and Sanctions, quality-assures remediation, and finishes EDD to a standard that withstands scrutiny.