The difference between the two
A health check refers to a high-level review of the design of a framework and can identify major problem areas in a framework. A maturity assessment is more advanced and provides a detailed review of a firm’s framework which includes the testing of the effectiveness of the framework itself.
Health Check
Maturity Assessment
Increase effectiveness,
focus on efficiency
To optimise firms’ FC controls, require an increase in effectiveness of processes along with a dedicated focus on high efficiency which will facilitate sustainable processes to demonstrate effective FC controls under scrutiny.
Firms must also view the improvement of their FC controls as a good commercial investment by focusing on the business advantages these could have for the firm.
Developing Effective Financial Crime (FC) Frameworks
The following directional indicators provide a high-level overview of the implementation and ongoing assessment of sustainable FC controls.
Assessment of FC risk & controls effectiveness (“FCRA”)
Understand the FC risk and the effectiveness of existing controls.
Create and maintain a library of existing FC risks & controls (tested & untested)
Conduct the mandatory annual FCRA, to drive decisions on: Improvements /transformations; Resources; Management of gaps and de-risking activities; Prioritisations and budgets; MLRO report.
Cost / benefit analysis and assessment of FC controls
Provide clearer understanding of the real cost of compliance.
Continuous risk/benefit assessment to drive controls enhancement and optimisation across FC operations (KYC/KYCC, TM, Screening, escalation);
Effectiveness of FC risk and controls reporting (MI – complete,
accurate and timely);Costs and impact analysis on:
De-risking – cost/benefit, strategy, action;
Customer experience
FC specialist resources and activities (FC ops)
FC activities as part of BAU.
Optimisation of FC controls - Sustainability
Improve the effectiveness and efficiency of FC controls driving sustainability.
Prioritisation & decision – FC governance - supported by complete, accurate & timely MI;
Budgets – Senior executive and board approval
Supporting resources planning for 6 months/12 months/3 years to
support:Lean FC governance and robust 3LoD structure and capabilities;
Clear and realistic objectives taking into consideration the 10
universal outcomes of Principled Performance;Adequate resources with the necessary skills and expertise to drive
high performance.
Automation focus on optimisation across:
FC operational activities; and
Assessment and reporting.
Assurance and Testing
Assess, measure, and provide ongoing assurance.
Development of assurance plan and control testing – assess and measure;
Reporting into a functional FC Governance structure to support decisions:
Executive decisions;
Committees & forums.
Escalation and decision on tactical/planned improvements.
