Ongoing assurance of a bank’s financial crime due diligence, including thematic enhancements

The bank had completed a series of remediation measures relating to its financial crime framework throughout and following a Skilled Person reporting cycle. The Board and senior management wanted to ensure embedding and sustainability of the past remediation, and beyond this, continuous improvement of the key financial crime framework.

This is in the context of resource changes and enhancements in challenging market conditions.

Working with the bank’s first and second line of defence team, we designed a programme of sample-based tests of all key aspects of the bank’s ongoing due diligence activities to be conducted on a monthly basis. By including sample-based reviews of some work already sample checked by the second line, as well as work that hadn’t been subject to second line sample checks, we were able to assess the effectiveness of both these lines of defence.

We designed a reporting dashboard that provides the bank’s management team with a simple overview of the overall results, and the trends over a period of time.

We have identified trends in different team’s performance, and repeat causes of defects, allowing for team and subject specific training to be designed and delivered on a focused basis.

The bank has leveraged our regular trend and thematic reporting to sustain the quality of enhancements previously made, and to identify the key areas for further improvement.

Through focused training interventions (some internal and others facilitated by our review team) the bank has consistently achieved stretch target quality levels. Taken in the context of exiting a Skilled Person process where there is always a risk of reduced attention, this is a significant achievement.

John Higgins

John Higgins

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