Case Study

Financial Crime Infrastructure Review

June 25, 2019

fscom was engaged by a leading financial institution in order to review and develop its existing AML/CTF infrastructure and, more widely, to provide assistance with the practical implementation of all suggested policy and process improvements.

Project background and objectives 

The UK FCA undertook an initial supervisory visit on the leading financial institution which identified systemic issues and, on the follow-up visit, identified that such issues remained in place. As a result, the financial institution invited fscom to outline our approach to how a review and development of its existing Financial Crime infrastructure might be achieved. The stated goal of the project was to address the immediate regulatory concerns, as well as to design and develop a fit-for-purpose BAU Financial Crime infrastructure.

Our approach

We provided a thorough appraisal of the current situation by way of an extended on-site audit and business risk impact assessment, including a review of all previous FCA findings as identified in its previous supervisory visits.

After this, we helped to both develop and deliver a robust and improved financial crime framework with appropriate systems and controls in place to support the existing risk infrastructure.


After the point of development, we assisted with the practical implementation of all recommended improvements before supporting key personnel on-site to understand the regulatory requirements and to transfer knowledge in order to embed a sound internal framework.

This included providing expert guidance on the regulatory environment in a manner that was both practical and straightforward, as well as an updated AML/CTF framework that covered both the strategic and operational elements within the business model.