Assessment of SM&CR arrangement in the UK subsidiary of an overseas bank
The bank had experienced several financial crime and risk and control related challenges linked to governance and oversight issues. We were asked to provide assistance to the bank’s management team to conduct the annual SM&CR review and certification process.
Our work focussed on key activities including:
– documenting previous Certification processes;
– highlighting gaps in process versus current FCA requirements and suggesting process enhancements where required;
– reviewing and/or helping compile Management Responsibilities Map, drawing on SMF Statements of Responsibility;
– providing advice on creating role profiles from job descriptions and aligning with Statements of Responsibility;
– designing questionnaires, briefing sheets and other artefacts to be used as part of the interviews and assessment;
– developing and agreeing with the bank management assessment criteria and a scoring mechanism;
– obtaining and reviewing staff HR information including job descriptions, performance reviews relevant to the agreed FIT assessment;
– seeking anonymous peer and/or 360 degree feedback relevant to the FIT assessment, COCON compliance, etc.;
– conducting competency-based interviews; and
– reviewing completed assessments with senior management in a joint workshop.
We were able to assist the bank in conducting their specific review and create a robust process with associated collateral for the bank to use in future reviews.