Financial Crime Prevention Control Framework
A UK bank engaged a Gracechurch Co-Founder to establish and operate a transformation programme to uplift their Financial Crime Prevention Control Framework in line with regulatory expectations.
Working in conjunction with the newly appointed Money Laundering Reporting Officer; the initial tranche of activity developed a comprehensive current state assessment and a gap analysis against relevant law, regulation and guidance.
The second tranche of activity, utilised the gap analysis and an independent controls effectiveness review, to deliver a multi work-stream transformation programme and a detailed implementation plan. Programme governance included the production of regular milestone based status reports for submission to the Financial Conduct Authority.
The transformation programme incorporated dedicated work-streams and associated delivery / implementation plans for a number of the primary Financial Crime Prevention controls;
• Financial Crime Policies, Procedures and Standards;
• Electronic Identification and Verification;
• Sanctions and Embargoes Screening (both customers and payments);
• Automated Transaction Monitoring;
• Suspicious Activity Reporting;
• Financial Crime Risk Assessment;
• Country and Product Risk Models;
• Customer Risk Rating Methodology
• Customer Risk Rating Tool;
• Financial Crime Record Keeping.
The scope of the programme extended to the remediation of deficiencies that had historically compromised the effectiveness of the control framework;
• Data quality and completeness issues;
• Absence of risk ratings for the bank’s existing customer relationships;
• Gaps in Financial Crime record keeping;
The programme also included activities to transform the culture of the bank;
• Development and rollout of Financial Crime awareness training for all staff;
• Re-definition of the roles and responsibilities for staff in Financial Crime Prevention roles;
• Enhancements to governance committee structures;
• Enhancements to processes and procedures across the first, second and third lines of defence;
• Registration of the bank’s executives under the FCA’s Senior Management Regime;