Framework Reviews, Gap Analyses and Maturity Assessments
We independently review financial crime frameworks across the three lines of defence to assess alignment with relevant legal requirements, regulatory expectations and industry practice. Our reviews can include a structured gap analysis, an assessment of control design and effectiveness, and a maturity assessment to help firms understand where improvement is required. We focus not only on whether a framework exists, but on whether it is consistently applied, adequately evidenced and operating effectively in practice. Our findings are prioritised to help firms identify the areas requiring the most urgent or significant enhancement.
Governance and Oversight
Strong governance is central to effective financial crime risk management. We support firms in reviewing and designing governance arrangements that provide clear accountability, appropriate oversight and effective escalation. This can include committee structures, reporting lines, roles and responsibilities, senior management accountability and the quality of financial crime management information. Our approach balances regulatory expectations with arrangements that are proportionate and workable for the size, scale and complexity of the firm.
Policies, Standards and Control Frameworks
We support firms in developing and enhancing financial crime policies, supporting standards, procedures and control frameworks. Our focus is on ensuring that documentation is clear, coherent and aligned with both regulatory requirements and the way controls operate in practice. We can also assess whether policies and procedures are consistently applied and embedded across relevant business areas. Support may include a full documentation refresh programme or targeted enhancements following regulatory change, internal findings, business growth or changes to the firm’s risk profile.
Business-Wide and Customer Risk Assessments
We design, review and enhance business-wide risk assessments to ensure that they reflect the risks arising from the firm’s business model, products and services, customers, delivery channels, geographies and other relevant exposures. We also support firms with customer risk assessment methodologies and tools, helping ensure that they are risk-based, evidence-driven and capable of being explained to senior management, auditors and regulators. Our support can include methodology design, risk factor selection, scoring, weighting, documentation, governance, implementation and periodic review. Where a new or revised customer risk assessment generates remediation activity, we can also support the resulting programme.
Customer Due Diligence and Enhanced Due Diligence
We review and strengthen customer due diligence and enhanced due diligence frameworks across onboarding, trigger events, ongoing monitoring and periodic review. Our work can include customer and beneficial owner identification and verification, source of funds and source of wealth, politically exposed persons, higher-risk customers, complex structures, escalation, approvals, record keeping and quality assurance. We focus on how due diligence operates in practice, including the quality of risk assessment, evidence, decision-making and documentation. We can also support remediation where backlogs or control weaknesses have been identified.
Screening and Transaction Monitoring
We support firms in reviewing and enhancing screening and transaction monitoring arrangements. This can include sanctions, politically exposed person and adverse media screening, customer and payment screening, alert generation, thresholds, scenario design, investigation processes, escalation, governance and management information. We help firms assess whether systems and controls are appropriately calibrated to the firm’s risks, whether alerts are investigated consistently and whether decisions are adequately documented and subject to effective oversight.
Fraud Risk Management
Fraud is a key component of the wider financial crime framework and should be assessed in the context of a firm's products, customers, delivery channels and operating model. We help firms assess and manage risks including identity and application fraud, account takeover, payment and APP fraud, internal fraud, intermediary fraud, commission abuse and cyber-enabled fraud. Our support covers fraud risk assessments, governance, prevention and detection controls, investigations, customer interventions, complaints, management information and training. We also help in-scope payment service providers comply with mandatory APP scam reimbursement requirements and support organisations in strengthening their arrangements for the corporate offence of failure to prevent fraud.
Sanctions, Bribery and Wider Financial Crime Risks
We support firms in developing and reviewing proportionate arrangements for sanctions compliance, anti-bribery and corruption, and the prevention of the facilitation of tax evasion. This may include risk assessments, policies and procedures, screening arrangements, third-party and associated person risk, gifts and hospitality controls, escalation and reporting, governance, training and assurance.
Regulatory Engagement and Remediation
We support firms in preparing for and managing engagement with the FCA and other relevant authorities. This can include preparing for supervisory visits, responding to information requests, supporting responses to regulatory findings or skilled person reviews, and advising on remediation plans, governance and communications. Our approach helps firms explain their arrangements clearly, demonstrate how controls operate in practice and respond to identified issues in a structured and credible way.
Training and Capability Development
Effective financial crime frameworks rely on staff understanding their responsibilities and applying controls consistently. We design and deliver practical, engaging training tailored to the firm’s business model, risk profile and employee population. This may include mandatory training, role-specific training, Board and Senior Manager training, workshops and supporting guidance. We can also review existing training frameworks, identify gaps, help firms develop appropriate training plans and support the assessment of training effectiveness.
MLRO and Annual Reporting Support
We provide advisory support to MLROs, financial crime teams and senior management. This may include developing or reviewing MLRO reports, supporting Board-level reporting, advising on management information and governance, and providing technical input on complex financial crime matters. We also support firms in preparing and reviewing FCA financial crime returns, including REP-CRIM. This can include interpretation of the reporting requirements, data review, documentation of methodology and consideration of material changes or variances.
Financial Crime Change and Transformation
We support firms in delivering financial crime change programmes driven by internal findings, regulatory expectations, growth, restructuring, acquisition or changes to products and services. Our work can include target operating model design, policy and control enhancement, governance, implementation support, remediation, integration and capability development. We focus on practical and sustainable solutions that can be embedded within the firm and demonstrated to senior management, auditors and regulators.
