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P2 FinCrime is built on the foundations of P2 Consulting and FS 101, both challengers in their respective markets. By combining the Financial Crime expertise of the FS 101 team with the project and programme management skills of P2 consulting we offer the best solutions to clients without the Big 4 overheads.

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P2 FinCrime’s services span the regulatory change lifecycle for Financial Institutions – from advisory and operating model design, to systems evaluation and implementation with a heavy dose of operational performance improvement and remediation along the way.

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In the first of our ‘Ask the Expert’ series, Phil Rolfe, P2 Consulting’s CEO, interviews financial crime and compliance expert Peter Hazlewood.

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We’ve worked with clients across the sector and have gained excellent results – but don’t just take our word for it. Have a browse through some of the work we’ve done.

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P2 Consulting

P2 Consulting is a market leading business transformation consultancy. P2 provides the entire range of consultancy services for organisations engaged in business change. P2 works in partnership with clients to turn their business ambitions into reality, bringing a unique blend of leading-edge thinking and hands-on delivery.

Financial Crime Business Wide Risk Assessment

Based on our recent relevant experience P2 FinCrime were asked to support a challenger bank

14.02.20
The Situaton
  • The organisation had received negative feedback following a recent audit and subsequent regulatory visit
  • As a result, they were initiating a review of key Financial Crime controls
  • A key foundation stone was the Financial Crime business Wide Risk assessment.
Issues
  • Historically the Financial Crime elements of the Business Wide Risk Assessment had been embedded in a wider exercise
  • It was therefore difficult to establish the specific Financial Crime risk profile the business was facing due to them being combined with other risks
  • Following on from that actions to mitigate/resolve FC specific risks were not easily identified and could not be evaluated, and changes subsequently tracked.
How P2 FinCrime helped
  • Reviewed the existing BWRA methodology to provide the framework to be adopted
  • Designed a Financial Crime BWRA approach that was appropriate to the size of the firm
  • Established the key drivers for Financial Crime risk across
    • Anti-Money Laundering
    • Sanctions
    • Bribery & Corruption
    • Fraud
  • Trained key bank staff on the new approach, drivers for change and objectives
  • Designed and held initial workshops with key divisional leaders to drive out specific risk areas for each division
  • Led follow up workshops that took the identified risks and sought to design mitigation strategies in the short, medium and long term
  • Documented all approaches, investigations and findings to a standard that would meet internal and external scrutiny
  • Supported the design of the BUA process to maintain the FC BWRA in future.
The Outcome
  • As a result of the review and workshops, several control gaps were identified by team members and actions taken to mitigate in the short term and close in the medium term
  • The bank now has a tried and tested Financial Crime BWRA framework that is the foundation for identifying, evaluating, reporting, tracking and mitigating related risks
  • It has an up to date view of the Financial Crime risks it faces
  • The bank has used the FC BWRA results to support investment cases that mitigate and ultimately resolve risks that are outside appetite
  • The new baseline has been reported to the bank risk committee and the approach and outcomes have been shared with the appropriate internal and external stakeholders.
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