The design of a firm's financial crime framework should be informed by findings of an appropriate risk-assessment, with resources allocated and risk mitigation measures in place, which reflect senior management priorities and risk appetite.

An effective framework should ensure that senior management is informed of where risk is in the business, the nature of controls in place, assurance based reporting on the effectiveness of such controls and importantly, the arrangements in place to identify new/emerging risk, to reduce the likelihood of a firm falling victim to an inadequate control framework.


Financial Crime strategy should be clearly articulated and cascaded across the firm, via:

  1. Policy - Setting out senior management expectations and tone-from-the-top (re: bribery, fraud, dishonesty, market abuse and money laundering)
  2. Procedure - Documented controls that underpin policy requirements and which include clarity of responsibility for their on-going maintenance, review and refresh
  3. Assurance - Measures to test and assure policy compliance and procedure implementation; relevant to the firm's operating environment and identifiable risk


Senior Management must ensure that appropriate measures are in place to:

How we can help you

In addition to financial loss and potential impact on profitability, Financial Crime is a significant threat to a firm's standing and reputation. Particularly when associated with a failure to comply with a core framework regulatory or governance requirement.

FCRM advises clients on their financial crime framework. We also assist clients to manage relationships with regulators when identifying, preventing and responding to financial crime risk in the operating environment; this may include assessing content and coverage of systems and controls for financial crime.

Integrity in Business Practice