Scenario
A UK digital bank required immediate, short-term reinforcement of its Financial Crime function to manage operational demand and regulatory risk during a period of transition. Square 4 engaged and deployed a team of 31 experienced Financial Crime investigators to support the bank in its response.
The team was tasked delivering the firm’s end-to-end financial crime controls across personal and business customers, covering Transaction Monitoring, Enhanced Due Diligence (EDD), sanctions and screening activity, and senior-level decision making. The engagement focused on maintaining high standards of regulatory compliance, protecting customers from harm, and ensuring continued adherence to obligations to the National Crime Agency (NCA) and other regulators.
Actions
Square 4 team of seasoned Financial Crime professionals possessed deep expertise across the full investigation lifecycle. The individuals:
- Managed and executed end-to-end Transaction Monitoring, Enhanced Due Diligence (EDD), EDD sign-offs, and customer screening, including Adverse Media and PEP checks, for both personal and business customers
- Conducted robust EDD reviews at onboarding and in response to trigger events
- Investigated payment screening alerts, assessing exposure to sanctions, high-risk jurisdictions, and prohibited activity
- Analysed potentially unusual or suspicious behaviour flagged by transaction monitoring systems
- Reviewed and resolved alerts relating to fraud, sanctions, and identity risks.
- Provided senior-level EDD sign-off to ensure consistent and defensible risk decisions
- Escalated concerns by submitting Suspicious Activity Reports (SARs) to the NCA where appropriate
- Took decisive, compliant action on customer accounts, including restricting access to fraudulent funds, returning funds to victims, and closing accounts where required
- Identified and shared emerging financial crime risks and trends with senior investigators and technical managers
Results
The Square 4 team ensured operational continuity and strong regulatory outcomes throughout the engagement. Key results included:
- Sustained delivery of high-quality financial crime investigations during a critical resourcing transition
- Timely identification, escalation, and reporting of suspicious activity
- Effective mitigation of sanctions, fraud, and money laundering risks across personal and business customer portfolios
- Protection of customers through the restriction, recovery, and compliant return of fraudulent funds
- Consistent senior-level EDD decision-making that reduced residual risk and strengthened governance
- Actionable insight into emerging financial crime risks, supporting ongoing control and policy enhancement
