About Us

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.

What We Do

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.

Insights

Understanding the challenges that keep our clients awake at night is essential. In this section we demonstrate our expertise at solving your problems. We have deep insight into the business and technology issues facing all sectors.

Ask the Expert

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

Case Studies

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.

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.

Dear CEO

In its most recent ‘Dear CEO’ letter to UK retail banks, the FCA has once again highlighted that it has concerns over financial crime control frameworks within many organisations that it regulates.

Despite years of warnings, prosecutions and some eye-watering fines, some organisations are still not investing sufficient time and energy into combatting financial crime. In its most recent ‘Dear CEO’ letter, the FCA advised businesses to complete gap analyses against five common weaknesses: Governance and Oversight, Risk Assessments, Due Diligence, Transaction Monitoring and Suspicious Activity Reporting (SARs) by 17 September 2021.

Is the plan that was developed in response to this letter robust, and are you ready to execute it? If you’re unable to get internal resource to fix this issue, P2 FinCrime has the experience and expertise to help you, today.

 

 

Risk Assessments

Business Wide Risk Assessments (BWRA):

  • The quality of BWRAs has been poor
  • Insufficient detail on financial crime risks
  • Inadequate assessment of inherent risk and mitigating controls
  • Lack of rationale to support residual risk and conclusions

Customer Risk Assessment (CRA):

  • Too generic to cover the different types of financial crime risks
  • Little differentiation to money laundering and terrorist financing risks
  • Discrepancies in how the rationale for specific risk ratings is decided and recorded by firms
  • Lack of documentation recording key risks and methodology
 
Governance & Oversight
  • Ownership of key controls: run by the head office/group functions are often reliant on ready-made controls, frameworks and products. Senior management is often unable to demonstrate assurance work undertaken and/or understand the actual processes and controls
  • Senior management sign off: firms cannot always evidence this level of governance, especially where higher risk factors are identified or where approval from senior management is mandated and lacking rationale for acceptance
 
Customer Due Diligence & Enhanced Due Diligence

Customer Due Diligence (CDD):

  • Not adequately performed or recorded
  • Lack of information on the purpose & intended nature of a customer relationship & assessment of that information

Enhanced Due Diligence (EDD):

  • EDD is weak and does not always mitigate the risks posed by the customer
  • Some instances of a PEP relationship but no evidence on adequate assessment of source of wealth (SOW) and source of funds (SOF)
  • Firms did not always assess the level of risks posed by a PEP and tailor the extent of their due diligence
  • Confusion around the purpose of obtaining SOW and SOF information, often requesting, obtaining & verifying the same documents to satisfy these two distinct requirements
 
Transaction Monitoring
  • Group-led transaction monitoring solutions which have not been calibrated appropriately
  • Transaction monitoring systems based on arbitrary thresholds, often using off-the shelf calibration provided by the vendor
  • Lack of understanding of the technical set up of transaction monitoring systems
  • Lack of regular assessments of data feeds and the data integrity of the system
  • Rationales supporting the discounting of transaction monitoring alerts require strengthening, often fail to demonstrate the level of investigation undertaken or record a sufficient explanation as to why activity is no longer considered unusual
 
Suspicious Activity Reports (SARs)
  • Instances where the process by which firms’ employees can raise internal SARs to the nominated officer is either unclear, not well documented or not fully understood by staff
  • Often firms are unable to adequately demonstrate to us their investigation, decision-making processes and rationale for either reporting or not reporting SARs to the National Crime Agency
  • In one example, a customer may have been alerted to money laundering concerns due to investigators not being appropriately trained in how to investigate potential suspicious activity
 

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