Financial Crime Business Wide Risk Assessment | Case study

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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