Why Choose Us?

We create value through a forward-looking approach to risk and compliance

Clients will benefit from using MCB's services for the following reasons:

  1. Bespoke, tailored and specialised regulatory compliance solutions: As their regulatory compliance partner, MCB’s consultants put themselves in the clients’ shoes and take the time to understand their business, objectives, organisation and culture, and accompany them on their growth journey. Solutions are tailor-made based on a deep understanding of business requirements, not just an off-the-shelf programme. Working seamlessly with the client’s team, we deliver pragmatic and cost-effective solutions which minimise regulatory burden and are tailored to their specific situation and requirements.

  2. Pragmatic and experienced partners: MCB’s consultants have a sufficient number of years’ experience of understanding clients’ needs in industry across a range of sectors and business models, covering a broad spectrum of regulatory compliance topics.  Bringing to the table multidisciplinary consulting skills and experience, we execute and get things done and provide you with practical and actionable solutions, not just reports.

  3. Thought leadership, peer learning and development: Our regulatory compliance specialists are at the forefront of regulatory developments, frequently contributing to discussions, consultations, events, workshops and lectures.  We make available to our clients best practice insights gained from working with peers in their sector. We deliver effective regulatory training solutions for all levels of a firm from senior management to operators.

  4. Esoteric knowledge of an emerging asset class: Specialist advice in regards to a nascent asset class, cryptoassets, gives MCB a competitive advantage over its competitors. MCB’s consultants undergo continuous professional development to keep their skillset, knowledge up to date for the purpose of providing clients with a top-tier service. This includes a unique understanding of the main problem drivers and problems and consequences.

 

Thought Leadership

Creation, sharing and transfer of knowledge

MCB actively participates in the creation, sharing and transfer of new knowledge in the cryptoasset sector. The innovation potential inherent in MCB's consulting activities derives from its potential role as a knowledge broker.

Challenges facing cryptocurrency and the path forward

MCBorrelli Advisors Limited (2021)

Overview of the Internet of Value (IoV) and other technological developments

Smart contracts, Decentralised Applications (DApps), and Initial Coin Offerings (ICOs)

MCBorrelli Advisors Limited (2021)

Overview of the value of Initial Coin Offerings (ICOs) and the strengths/weaknesses of Decentralised Applications (DApps)

UK Financial Services Framework

MCBorrelli Advisors Limited (2021)

High-level conceptual overview of the UK financial services regulatory framework for cryptoassets

Anti-Money Laundering (AML) Risk assessment framework

The Law Society (2021)

Summary of considerations for firms' in preparing an AML risk assessment framework.

Know Your Client (KYC) Research

Global Digital Assets (2020)

Summary of relevant points in regards to KYC policies, procedures, processes and other factors

National Risk Assessment (NRA) of Money Laundering and Terrorist Financing 2020

MCBorrelli Advisors Limited (2021)

Summary of the UK Government's most recent NRA of money laundering in regards to Cryptoassets

Call for Evidence (CfE): Review of the UK's AML-CTF regulatory and supervisory regime

MCBorrelli Advisors Limited (2021)

Summary of the UK Government's most recent CfE of the current Anti-Money Laundering (AML)/Countering the Financing of Terrorism (CTF) regulatory and supervisory regime.

Consolidated assessment rating: United Kingdom (UK)

MCBorrelli Advisors Limited (2021)

Summary of the Financial Action Task Force's (FATF) Mutual Evaluation Report (MER) of the UK, with reference to Cryptoassets.

Amendments to the Money Laundering Regulations 2017 Statutory Instrument 2022: Consultation

MCBorrelli Advisors Limited (2021)

Summary of the UK government's consultation on the proposed amendments to the MLRs 2017 in regards to Cryptoassets.

Financial Conduct Authority (FCA): First Supervisory Notice - Binance Markets Limited (BML) - 25 June 2021

MCBorrelli Advisors Limited (2021)

Summary of the FCA's First Supervisory Notice issued against Binance Markets Limited (BML) in June 2021.

HM Treasury: Regulatory Framework for Approval of Financial Promotions: Consultation Response - June 2021

MCBorrelli Advisors Limited (2021)

Summary of the responses received to the consultation held by HM Treasury on the new Regulatory Framework for Approval of Financial Promotions

International Organisation of Securities Commissions (IOSCO): The use of artificial intelligence and machine learning by market intermediaries and asset managers – Final Report (FR06/2021)

MCBorrelli Advisors Limited (2021)

Summary of the Final Report (FR) produced by IOSCO relating to how market intermediaries and asset managers use Artificial Intelligence (AI) and Machine Learning (ML) and the associated risks

Her Majesty's Treasury (HMT): A new chapter for financial services

MCBorrelli Advisors Limited (2021)

Summary of the publication by HMT setting out the UK government’s vision for the financial services sector.

House of Commons (HoC) Treasury Committee: The Future Framework for Regulation of Financial Services

MCBorrelli Advisors Limited (2021)

Summary of the report by HoC Treasury Committee setting out its view on how the future framework for the regulation of financial services should be designed, how it should be scrutinised, and where responsibility for regulation should sit.

Her Majesty's Treasury (HMT): Financial Services Future Regulatory Framework Review - Phase II Consultation

MCBorrelli Advisors Limited (2021)

Summary of the consultation by HMT exploring how the United Kingdom (UK) regulatory framework for financial services needs to adapt to its new position outside the European Union (EU).

 

Consulting Approach

MAL has constructed an array of innovative approaches to deal with clients' compliance and regulatory challenges

MCB adopts a 'reverse engineering' approach whereby current (or anticipated) challenges are framed in terms of its service offering. Therefore, MCB's services are tailored to solving specific issues raised by cryptoasset market participants.  

Overview

Framework approach

High-level conceptual diagram showing how MCB aligns its service lines to client needs

Token Classification

Framework Approach

High-level conceptual diagram showing MCB's approach to classifying cryptoassets under the applicable regulatory regime(s)

Regulatory Requirements vs. MAL's Service Offering

Framework Approach

High-level conceptual diagram showing how Clients’ needs have been benchmarked against some of MCB’s services

Client Engagement Process

Framework Approach

High-level conceptual diagrams showing how MCB's approach to consulting

Volatility, Uncertainty, Complexity and Ambiguity (VUCA)

Framework Approach

High-level descriptive account of MCB's approach to countering VUCA in the UK cryptoasset market in regards to financial services regulation.

 

Roadmap to Compliance

Providing you with a fit-for-purpose framework, which can provide longevity to a range of applications, both in terms of cost and maintenance.

MCB will provide you with a framework to ensure regulatory compliance. MCB's approach encompasses the following: 

Review existing systems, controls policies, procedures and processes​

Determine appropriate level of liaison for client engagement and frequency of meeting(s)

Consider training and education for staff to embed the principles of compliance

Consider review and update of policies, processes and procedures

Make policies, processes and procedures publicly available to all internal members of staff

Align policies, processes and procedures with regulatory obligations and requirements

Conduct a gap analysis between business and operating models and the provisions of the applicable code(s), regulation(s), legislation, rule(s) and law(s)

Identify relevant business activities and determine which regulatory obligations and requirements apply

Connect relevant internal business areas and set up a project group

Review the content of the applicable code(s), regulation(s), legislation, rule(s) and law(s)

 

Problem Tree

MAL has a unique understanding of the main problem drivers, problems and consequences in the Cryptoasset sector. These include, but are not limited to:

Drivers

  1. Lack of certainty as how existing rules apply;

  2. Absence of rules; or

  3. Diverging rules for crypto not covered by existing rules.

Problems

  1. Regulatory obstacles to the use of

  2. DLT and potential gaps in existing legislation;

  3. Consumer/Investor Protection risks and risks of fraud;

  4. Market Integrity risks;

  5. Market fragmentation/risks to level-playing field; or

  6. Monetary

Consequences

  1. Missed efficiencies in the issuance/trading/post-trade areas;

  2. Missed funding opportunities for start-up companies (through low level of ICOs/STOs); or

  3. Missed opportunities in terms of financial inclusion and cheap, fast, efficient payments.

 

Top 5 Regulatory Challenges

Source: Global Digital Finance (2021)

MAL will help clients navigate and overcome the main regulatory challenges faced in regards to cryptoassets.

#1

Inconsistent or unaligned cross-border regulatory guidance

#2

Lack of clarity on regulatory perimeter

#3

Not all market actors are regulated, creating commercial challenges to partner/collaborate

#4

Ability to meet regulators requirements

#5

Limited engagement by regulators with industry

 

Compliance Challenges

Anti-Money Laundering (AML)

Reduce Or Eliminate Your Compliance Challenges. Data sourced from Oxford Economics (2021).

47%

Increase alert volumes/suspicious transactinos

43%

Reduced controls and compliance monitoring capabilities

36%

Increased manual compliance workload/activities

 

Compliance Challenges

Regulatory Compliance

Reduce The Percentage Of Revenue Spent On Regulatory Compliance. Data sourced from Kroll (2021).

14.3%

>1% Revenue

23.9%

1% - 5% Revenue

13.8%

6% - 10% Revenue

7.9%

11% - 20% Revenue

1.6%

20% - 25% Revenue

5.9%

>25% Revenue

32.9%

Not Sure

 

Cost Reduction

Cost Saving Service

Reduce the one-off costs of compliance with financial services legislation. Substantive compliance costs encompass those investments and expenses made by clients to comply with substantive obligations or requirements contained in a legal rule.

These include, but are not limited to: (i) Familiarisation with obligations; (ii) Staff recruitment costs; (iii) Training of personnel; (iv) Legal advice; (v) Consultancy fees; (vi) Investment in/updating Information Technology (IT); (vii) Project management; and (viii) Other costs. Data sourced from the European Commission (2019). 

0.13%

MAD/MAR

Median one-off cost of compliance for small organisations as a % of total operating costs (financial markets)

0.22%

EMIR

Median one-off cost of compliance for small organisations as a % of total operating costs (financial markets)

0.80%

MiFID I/MiFID II/MiFIR

Median one-off cost of compliance for small organisations as a % of total operating costs (financial markets)

 

Cost Reduction

Data Driven Approach

MAL has a unique understanding of the, and the extent to which, factors affect general compliance costs and supervisory costs linked to financial services legislation. Data sourced from the European Commission (2019).

>60%

General compliance costs

Factor: Number of requirements
Weighting: 5 - Very Significantly

>30%

General compliance costs

Factor: Timing of Legislative Changes
Weighting: 4 - Significantly

>30%

General compliance costs

Factor: Short transition period for compliance with new legislation
Weighting: 5 - Very Significantly

>25%

Supervisory reporting costs

Factor: Inconsistency/lack of clarity of requirements
Weighting: 4 - Significantly

>20%

Supervisory reporting costs

Factor: Lack of (adequate) technical guidance/specifications
Weighting: 4 - Significantly

=>40%

Supervisory reporting costs

Factor: Extent to which compliance can be automated
Weighting: 5 - Very Significantly

 

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