Due diligence of exemptions for a TCSP

Client profile

A trust, corporate & funds service provider based in the Channel Islands.

Our client wanted assurance that when exemptions were relied upon by its administrators, exemption usage was appropriate.

The challenge

Our client has mature compliance processes and a well-trained staff base. Management and the Compliance team had noted that more reliance was being placed on due diligence exemptions by staff. The leadership team wanted to incorporate exemption validity testing into their client life cycle risk management solution to ensure measures applied were circumstantially suitable.

How RiskScreen helped

We conducted research into local exemptions relating to reliance on third parties and when the application of simplified due diligence was permissible. The research findings were converted into a series of operational logical appropriateness testing steps. Once approved by the client, these steps were incorporated into the system set-up. The testing steps were accompanied by additional controls to pro-actively alert the Compliance team with respect to user trends in this area to allow for the provision of focused staff training if needed.

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