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

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