Pierre le Jeune d'Allegeershecque’s Post

View profile for Pierre le Jeune d'Allegeershecque

Associate Director at Aperio Intelligence

Some key takeaways from the French banking regulator's €1 million fine on SocGen's BaaS company Treezor:   - Out of a sample of 30,000 clients, 99.8% were assigned a low or "moderately low" risk, leaving just 28 clients as medium or high-risk.   - The first automated KYC platform Treezor used would flag clients exclusively based off a politically exposed person (PEP) check; no litigation, regulatory, sanctions, or other checks. The company later acquired SocGen's group-wide KYC platform, but implementation was patchy and at times Treezor compliance teams were using both platforms in parallel.   - Material information easily identifiable through EDD was missed in a number of KYC cases picked for review at random by the regulator; three of the cases had not picked up that the respective clients had previously been given prison sentences. Treezor's legal team responded that, in the first case, the media coverage reporting on the prison sentence could not have been used to inform a client risk rating since media report was often unreliable; in the two other cases, it argued that the sentences were historical and as such could not affect the clients' risk ratings.   There is no doubt that Treezor should have used a more capable #KYC tool, and complemented the KYC tool with human-driven analysis and complementary research. However, it is debatable whether a €1 million fine and a formal reprimand for the largest BaaS company in France will be enough of a deterrent for companies in similar situations to spend the money and time required to establish best-in-class AML/CFT processes. Read our full article here: https://lnkd.in/e8s6sH_3

Financial Crime Digest

Financial Crime Digest

aperio-fcd.com

To view or add a comment, sign in

Explore topics