Financial Crime Quarterly: Tracking Threats and Opportunities
Where does it all start to go wrong? The answer, too often, is right at the top of the organisation. When we are called upon to review a financial services firm for a regulator in response to financial crime concerns, the pattern of failings most commonly starts at board level.
Welcome to the second edition of our Financial Crime Quarterly. We hope you’ll find these pages packed with topics of interest, all drawn from our latest work in the field. Now read on...
The responsibilities of the directors of a financial institution towards financial crime are becoming ever more onerous. Backed up by both changes to the Companies Act and the Senior Managers and Certification Regime (SM&CR), the pecuniary, career and occasionally custodial penalties for getting it wrong reach all the way to the lofty heights of non-executive directors. As a board member, what is expected of you?
Well, a good starting point is for the firm to have a clear and current holistic assessment of the risks the business is exposed to and a formal appetite statement for each class. Whilst boards seem to find some kinds of risks easy to understand, the concept of having an ‘appetite’ for financial crime risk strikes some as perverse. And yet, every time we do business with a third party, we are exposing ourselves to the risks inherent in that business, and amongst those risks is potential exposure to financial crime.