KYC lookback for an international bank’s London capital markets business

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.

BEFORE — Lookback backlog & uneven remediation
Capital markets KYC files · remediations of uneven quality · EDD not closed Batch A · open “Remediated” · unverified High-risk · EDD thin Legacy packs Screenshots · email trails · incomplete SoW / SoF notes MLRO scrutiny ? Head of AML & Sanctions ? 2LOD sign-off ? Files “through remediation” still fail independent QA Higher-risk customers · EDD gaps · forensic recon incomplete
AFTER — QA’d KYC & EDD ready for scrutiny
Second-line lookback · forensic reconciliation · EDD close-out GRT financial crime specialist · inside 2LOD Independent QA Remediated KYC file review Enhanced due diligence Higher-risk customers QA’d KYC files PEPs Sanctions Adverse media Customer risk assessment Source of wealth Source of funds First-line risk acceptance · evidenced MLRO ready AML & Sanctions Head review Lookback close-out Same GRT resource stayed through programme close-out Specialists join the bank’s team — not a half-finished handoff

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.

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