Effective governance requires senior management to be actively engaged in addressing financial crime risk, supported by risk-sensitive internal controls, designed with relevance to the operating environment.
The level of seniority and extent of on-going senior management engagement will differ between firms', influenced by factors, such as: (a) complexity of management and/or operating structure; (b) clarity of messaging across the organisation of senior management risk-appetite (i.e. being clear on what is not acceptable); (c) clarity of responsibility across the three lines of defence; and (d) effectiveness of assurance testing arrangements in place, to identify financial crime risk.
Prevention should be reflected in clear messaging by the Board, that:
Senior Management must ensure that appropriate measures are in place to:
FCRM assists clients to identify and respond to financial crime risk in their operating environment.
We assist with defining and embedding financial crime frameworks, underpinned by policy and procedure covering: prevention, detection and response to financial crime.
We support internal risk and compliance functions to assess risk and assurance test existing arrangements (e.g. via gap-analysis or benchmarking), or to plan and prepare for regulatory visit or review.