CONSULT

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.