The Supervisors’ expectations are steadily rising. With them, remediation work is becoming more extensive – and more critical to avoid adverse regulatory action.
Regular independent audits and mandatory internal reviews now need to be carried out within reasonable timeframes. Their implementation should be supported by evidence, such as governance reports.
The Supervisors increasingly want to see that remediation extends to practical implementation and successful testing through robust controls.
We help you resolve compliance issues quickly and effectively, focusing on long-term durability and cost-effectiveness.
Remediation following an independent audit requires particular care. Your Annual Report to your Supervisor includes your confirmation of whether you have carried out the remediation work highlighted by your auditor.
Remediation work recommended by your Supervisor is also critical, and may involve ongoing communication with them.
We advise on remediation work and, where required, manage its implementation and communicate with your Supervisor on your behalf as necessary.
We also train reporting entity Compliance Officers and associated staff on new processes flowing from a remediation, and can help you design training for your compliance team to deliver.
Remediation work varies greatly and depends on the number and degree of adverse findings from your auditor or Supervisor, as well as the nature and size of the reporting entity. It could be a complete overhaul or just a few tweaks to achieve satisfactory compliance.
Our shortest remediation project was 4 hours with a small law firm. Our longest was 8 months with a multi-national investment house managing a broad range of fund types. It also depends on whether you tackle only the necessary fixes or the auditor's full suite of recommendations.
Remediation work sometimes requires associated wider compliance improvements. We can help there too.
Robinson Legal's team are litigation specialists who bring unparalleled AML/CFT experience to our clients. We have extensive prosecution and defence experience, and have advised government, corporate and individual clients on financial crime, AML/CFT, the full range of criminal cases and regulatory investigations and prosecutions.
Our Principal, Marty Robinson, co-wrote the legal text The AML/CFT Regime: A Practical Guide. Marty has spent two decades in financial crime and associated areas, including investigation and prosecution work at the UK Serious Fraud Office as an Investigative Lawyer and acting as Principal Solicitor at New Zealand’s Department of Internal Affairs, a Crown Prosecutor at the Crown Solicitor’s Office, and a criminal defence and civil litigation lawyer on his own account and with Robinson Legal.