Financial Crime

Financial Crime Framework

• Governance
• Policies and procedures

Customer Lifecycle

• Onboarding including Customer Due Diligence, Enhanced Due Diligence, Customer Risk Assessment
• Transaction Monitoring – technology, rule/scenario configuration, discounting best practice
• Periodic Review
• Dormant and blocked customers, offboarding

Sanctions and PEP Compliance

• PEP and Sanctions related policies
• PEP and Sanctions screening – technology, procedures, discounting best practice

Financial Services

• Trade finance
• Correspondent banking
• Payment services and electronic money
• HNW banking
• UK branches and subsidiaries of non-EEA banks
• Higher risk jurisdictions

Anti-Bribery Compliance

• UK Bribery Act compliant policies – development, gap analysis
• UK anti-bribery and corruption (ABC) best practice / procedures – compliance with MoJ guidelines
• International ABC policies and procedures – compliance with international legislation and regulation, for example:
  • US Federal Sentencing Guidelines
  • French AFA Guidelines

Training and Team Development (first and second lines of defence)

• Board workshops
• Training strategy
• Training Needs Analysis (TNA) – Financial Crime focused or general
• Training Plans
• Training design
• Training delivery – bespoke in person or virtual workshops

Quality Assurance and Internal Audit (third line of defence) Services

• IA outsourcing and co-sourcing
• IA Annual Plans – Financial Crime thematic reviews or integrated into general review
• IA work programme design – Financial Crime thematic reviews or Financial Crime steps integrated into general reviews
• Quality Assurance (QA) during or following Skilled Person reviews, general independent QA:
  • Outsourced or co-sourced CMP
  • Onboarding and periodic review QA
  • Correspondent bank and trade finance DD QA
  • Transaction monitoring discounting QA