Financial Crime

Economic crime surveys show that financial crime is one of the most commonly experienced issues by businesses and individuals. It’s multifaceted, touches many points in a business and crucially is evolving.

This is a particular (whilst not unique) challenge for financial services firms where they continue to be in the headlines as victims of financial crime. The ramifications for a business are massive: reputational harm; investigations and fines; regulatory reviews; suspension of business; and loss of licence to operate.

Firms are required to have systems and controls in place to detect, prevent and deter financial crime and work within a detailed regulatory framework. Financial crime is a core area of regulatory attention.

Regulators continue to commission reviews into firms’ financial crime systems and controls. These reviews often find areas of weakness which require remediation and resolution.

Firms with a strong understanding of financial crime risk, the right system and controls and appropriate resourcing can:

Detect and report unusual or suspicious activity that might expose them to financial loss, increased expenses or other risks;
Avoid criminal exposure from entities who use or attempt to use their products and services for illicit purposes;
Fulfil the requirements of the regulators; and
Adhere to safe and sound practices.

Our Approach

We work with organisations to develop their people, processes and systems to prevent, detect and mitigate financial crime. We help them to build and implement programmes of change in readiness and in crisis situations to safeguard their reputation, remediate issues, enhance performance and build confidence. We provide advice, skills and technical expertise in financial crime including anti-money laundering, anti-bribery and corruption, sanctions, tax evasion, market abuse, fraud and the governance of these areas. Our team has big four, legal advisory, Skilled Person and wider assurance experience. They’re financial services practitioners who’ve worked together over many years and understand financial crime from an operational perspective. We also use other sector AML, PEP and sanctions experts with cross-sector knowledge of good practice. Our key areas of financial crime focus include:

Governance and oversight
Financial Crime organisation structure and development
Policies and procedures
Risk Framework (Risk Appetite; Business Wide Risk Assessment)
Monitoring
Customer lifecycle
Sanctions and PEP compliance
Training and team development (1LOD and 2LOD)
Quality Assurance
Internal Audit (3LOD)

Our Services

We help firms address financial crime through:

Skilled Person Reports

Reviews commissioned under Lot E: Financial Crime of the Skilled Person Panel or other Lots where the subject matter is primarily financial crime.

Remediation

Helping clients remediate findings and recommendations or implement programmes of change as a result of financial crime issues, reviews or enhancement projects.

Advisory

Giving clients expert advice and support on topics of financial crime e.g. preparation for reviews, designing and implementing Financial Crime frameworks, supporting licence application, systems enhancements and training.

Assurance

Providing quality assurance or independent internal audit support where financial crime is the area of subject matter focus.

Secondments

Providing resources to fill or bridge a gap in financial crime skills and capabilities (e.g. HoC, MLRO, analyst support, etc.).