Support can be provided at a variety of levels ranging from providing ad-hoc support to smaller organisations for a single day to providing additional support to in-house specialists in a large organisation as part of a project lasting many months.
Support can take a variety of forms, but always with the objective of preventing, detecting and resolving financial crime issues - some examples are shown below
PREVENT
Risk Management / Risk-based Approach
- Facilitate identification of objectives/obligations
- Facilitate the identification of risks
- Establish measures to assist the assessment of risk
- Establish strategy for managing risks
Policies – Draft / Review
- Financial Crime
- Money Laundering
- Financial Sanctions
- Bribery and Corruption
- Client Due Diligence (CDD / KYC)
- Transaction Monitoring
Procedures – Draft / Review
- Client Onboarding
- Screening (PEPs etc)
- Transaction Monitoring
- Suspicious Activity Reporting (SAR)
Training – Design / Deliver/ Assess
- Obligations – raising awareness of legal/regulatory obligations
- Policy – ensuring the organisation’s expectations are understood
- Procedure – ensuring that how the organisation’s expectations are achieved is understood
Advice / Guidance
DETECT
Risk Management
- Establish methods for reviewing performance of financial crime prevention strategy
Management Information / Reports
- Establish measures to assist the assessment of whether objectives/obligations (and policy) satisfied
- Establish measures to assist the assessment of whether procedures applied
- Establish measures to assist the evaluation of understanding
- Draft (or review) reports for management
Health-Check
- Independent review of performance of financial crime prevention strategy
- Independent review of performance of specific policies, procedures and training
Advice / Guidance
RESOLVE
Risk Management
- Establish potential causes where performance of financial crime prevention strategy is not as desired
Incident Response Plan
- Establish a plan of action should a significant financial crime incident arise to guide decision-making and communication
CDD / KYC Remediation
- If historical CDD standards are not satisfactory, a plan of action can be developed to ensure that any gaps are identified and remedied efficiently
Advice / Guidance
COFFEE-TIME CRIME CONSULTANCY
If you would like an informal discussion about financial crime matters or how we may be able to help, then I am happy to have an initial chat over coffee. If you need a slightly longer discussion, then biscuits or cake will almost certainly buy a little more time!
Feel free to Contact me to arrange.