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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