Anna Kostus

Anna Kostus is a financial crime regulatory expert who helps clients understand the changing supervisory landscape, build and implement strong controls and anti-financial crime capabilities.

Ms. Kostus has more than 12 years’ experience within the financial services industry in the UK, the Middle East and continental Europe. She has worked with a diverse range of clients from banks, private wealth and asset managers through to Money Service Businesses (“MSBs”) and gaming operators for whom she has delivered financial crime function reviews (including several s.166 Skilled Person Reviews) and led people and projects varying from responding to regulatory events and criticism through designing financial crime controls to providing regulatory advisory and delivering process improvements.

In addition to leading larger project teams, Ms. Kostus has provided clients with ongoing advisory support on a personal retainer-basis and has been seconded into interim financial crime SME roles. Most recently, she helped a London-branch of a major European bank prepare for an upcoming FCA regulatory visit and respond to the regulator’s criticism.

Ms. Kostus served as a Special Advisor on Financial Crime at a mid-sized European bank where she designed the process for the assessment and approval of high-risk clients and delivered targeted financial crime training and coaching to the firm’s senior management and risk-owners.

Relevant Experience:

• Led a multi-faceted AML and counter-terrorist financing (“CTF”) remediation programme for a subsidiary of a Swiss private bank, which included governance and systems and controls uplifts and oversight of the end-to-end Know Your Customer (“KYC”) back book remediation of the firm’s entire client population
• Delivered and implemented new Cross-Border Customer Due Diligence Standards for a large European bank, addressing the regulatory requirements of 12 jurisdictions
• Led the delivery of more than 10 Financial Crime/AML Control Framework Compliance Reviews and Regulatory Audits (including Skilled Person s. 166 Reviews and Executive Undertakings) for Tier 1 and challenger banks, private wealth and asset managers, MSBs and gambling operators
• Delivered AML/CTF business-wide risk assessments for a UK challenger bank and a development finance institution
• Re-designed a Governance Risk and Compliance (“GRC”) model for a European FinTech seeking to obtain a banking license.