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Consultancy - Systems & Controls

FCRM specialises in fraud prevention and anti-money laundering, providing risk and compliance services to clients in the regulated financial services sector. Regulators, such as, the Financial Services Authority ('FSA') require firms under their supervision to have risk-sensitive Systems and Controls ('SYSC') arrangements, to prevent financial crime.

FCRM works with clients to develop and maintain appropriate SYSC compliance arrangements for the prevention of fraud and money laundering, to enable client firms meet regulatory expectations. In particular, we assist clients to develop and maintain SYSC arrangements, that:

  • Reflect reasonable care and provide compliance with applicable requirements and standards of the regulatory system.
  • Counter the risk that a firm might be used to further financial crime.
  • Enable a firm to identify, assess, monitor and manage money laundering risk.
  • Provide governance and oversight of relevant fraud and money laundering risk.
  • Facilitate early warning of suspicion and red-flags, indicative of financial crime risk.
  • Are comprehensive and proportionate to the nature, scale and complexity of a client's business activity.
  • Provide compliance with the FSA's SYSC expectations (re SYSC 3.2.6.)
Pre-emptive reviews

As a specialist financial crime consultancy, FCRM is ideally positioned to assist firms identify, manage and respond to fraud, corruption and money laundering risk. We work with clients who expect (or anticipate) a review of their financial crime arrangements by a regulatory body, such as, the FSA, as part of an ARROW or thematic visit.

Through assurance testing or by adopting appropriate programmes of activity, clients can identify potential systems and control issues and take steps to reduce regulatory (or reputational) risk, ahead of a regulator's visit; whilst also reducing the risk of financial loss or possible enforcement action, caused by association with fraud or money laundering, or with systems and control weaknesses relating to financial crime.
Regulatory risk

The risk to earnings, capital or reputation from a significant failure to comply with a regulatory requirement or expectation.

For a significant event involving fraud, error or irregularity, a firm may have a regulatory reporting requirement where:
  • An employee - May have committed a fraud against a customer.
  • A person - May have committed a fraud against the firm, or acts with intent to commit a fraud against the firm.
  • Irregularities identified - In the firm's accounting or other records, whether or not there is evidence of fraud.
  • Suspicion - An employee may be guilty of serious misconduct concerning his honesty or integrity and which is connected with the firm's activities.
  • Systems and Controls - Where existing arrangements are insufficient to comply with regulatory requirements and standards.



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