MHA Financial Crime Reviews
We are all aware that the risk based approach to managing financial crime presents both an opportunity to target resources effectively and a challenge to ensure that the approach is regularly reviewed and updated to reflect changing legislation, regulation and risk levels. Such reviews and updates can represent a strain on limited resources and require a broader skill set than is required to manage day to day operational obligations.
There have been two key trigger events recently that should prompt all regulated businesses to review and update the robustness of their financial crime prevention strategies:
- Firstly, there is the Bribery Act, introducing fundamental changes to UK legal obligations, including the new corporate offence of "failing to prevent bribery" which can have a major impact across a number of areas including HR, sales, purchasing, AML policy etc.
- Secondly, the Shah v HSBC Court of Appeal ruling which has a major impact on the procedures for reporting suspicious activity.
More information on the requirements and impact of both is contained in our recent
MHA briefings
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The review process
MHA consultants have already carried out reviews and gap analysis for many UK and international clients; reviewing their financial crime (including AML/CTF) strategy and controls, benchmarking against legislation, regulation and good industry practice in similar organisations and against their own group policies/requirements.
We can provide an unbiased, third party, independent review from acknowledged subject matter specialists that demonstrates your organisation has a strategy in place that will effectively manage risks, meet obligations and satisfy scrutiny by the FSA or other relevant regulators.
In close collaboration with the MLRO/financial crime staff and senior management, MHA will:
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- Review and assess your financial crime risk profile, strategy, policies and related procedures;
- Identify any gaps; and
- Make appropriate pragmatic recommendations to reduce relevant risks.
We will provide you with an MHA client action plan which is dynamic and facilitates the tracking of recommended actions through to completion and sign off by senior management. It thus provides a comprehensive record of the assessment, the actions identified as necessary and the implementation of appropriate practical enhancements.
Time and budget
Prior to discussion, it would be misleading to provide an estimate. However because all MHA consultants are subject matter specialists, have held senior financial crime posts and have undertaken many similar projects before, most clients are pleasantly surprised at the speed, efficiency and low cost. Often an FCR will be completed within 5-6 consultant days but this does depend upon the size and complexity of the client’s business.
Key benefits
- Provides an assurance from a recognised expert that you are compliant
- Demonstrates prudent management in line with SYSC requirements
- Opportunity to benchmark your controls against industry best practice