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:

  1. Financial Crime is not tolerated (e.g. bribery, fraud, dishonesty, market abuse or money laundering)
  2. All reasonable efforts will be made to prevent and detect financial crime (including the potential for disciplinary action and/or referral to the authorities where appropriate to do so)
  3. Staff are encouraged to report suspicion/concern of improper activity (e.g. transactions, behaviour or operating practice)


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

How we can help you

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.

Integrity in Business Practice