The systems & controls of a regulated firm are often the most contentious for regulators as this is the area of the regulatory obligations that often falls short. However, the BWRA [see steps 1] has successfully identified all the financial crime risks; the Board / Senior Management has signed off, i.e. accepted the risks and updated Policies & Procedures.
The procedural stage has to articulate how the firm mitigates financial crime risks through its Systems & Controls. In turn, must document the procedures to ensure alignment with the systems and controls.
Unfortunately, too often, when the regulator conducts their reviews of regulated firms' systems & controls that have been put in place to reduce financial crime risk does not meet the regulatory test and is not aligned to its procedures.
FinCrime Protection works with firms to ensure that the risks identified from the BWRA (see Step 1) are aligned to the Policies & Procedures (see Step 2) and Controls.
On completion, will align your systems & controls to your BWRA, Risk Appetite Statement, Policies & Procedures and the next steps of the Virtuous Circle Model programme can commence:
Step 4: Training
Step 5: Reporting
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The Virtuous Circle Model
Five simple steps to ensure your business is protected from Financial Crime
Business Wide
Risk Assessment
policies &
procedures
controls
training
Reporting
International Compliance Association Testimonial
"He'll come in... show people where the problems are and say 'this is what you need to do'."
Dr. David Handy-Jenkins, the International Compliance Association Director of Quality Assurance Accreditation and Audit explains how FinCrime Protection solves problems
During the time Tyrone served as my Global Head of Sanctions, I always considered him to be the "go-to" person whenever I needed guidance on tricky issues.
Read MoreGeneral Counsel - International at BTG Pactual
Jill M. Wallach
General Counsel - International at BTG Pactual
Having worked closely with Tyrone I was impressed by both the depth of his knowledge of financial crime and his ability to work with all parts of an organisation. He has rare balance of technical knowledge and pragmatism.
Read MoreGroup Head of Financial Crime Compliance at Brooks Macdonald Group
Aaron Guilder
Group Head of Financial Crime Compliance at Brooks Macdonald Group
During the time Tyrone served as my Global Head of Sanctions, I always considered him to be the "go-to" person whenever I needed guidance on tricky issues.
Read MoreGeneral Counsel - International at BTG Pactual
Jill M. Wallach
General Counsel - International at BTG Pactual
Having worked closely with Tyrone I was impressed by both the depth of his knowledge of financial crime and his ability to work with all parts of an organisation. He has rare balance of technical knowledge and pragmatism.
Read MoreGroup Head of Financial Crime Compliance at Brooks Macdonald Group
Aaron Guilder
Group Head of Financial Crime Compliance at Brooks Macdonald Group
We have worked with Tyrone on a number of our AML/ Financial Crime projects over the last few years and he is a practical, knowledgeable colleague with a strong customer focus who we enjoy working with.
Read MoreExecutive Director - The Compliance Foundation
We have worked with FinCrime Protection Ltd on a number of our AML/ Financial Crime projects over the last few years and he is a practical, knowledgeable colleague with a strong customer focus who we enjoy working with.
Sandra Quinn
Executive Director - The Compliance Foundation
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During the time Tyrone served as my Global Head of Sanctions, I always considered him to be the "go-to" person whenever I needed guidance on tricky issues.
Read MoreGeneral Counsel - International at BTG Pactual
Jill M. Wallach
General Counsel - International at BTG Pactual
Having worked closely with Tyrone I was impressed by both the depth of his knowledge of financial crime and his ability to work with all parts of an organisation. He has rare balance of technical knowledge and pragmatism.
Read MoreGroup Head of Financial Crime Compliance at Brooks Macdonald Group
Aaron Guilder
Group Head of Financial Crime Compliance at Brooks Macdonald Group
During the time Tyrone served as my Global Head of Sanctions, I always considered him to be the "go-to" person whenever I needed guidance on tricky issues.
Read MoreGeneral Counsel - International at BTG Pactual
Jill M. Wallach
General Counsel - International at BTG Pactual
Having worked closely with Tyrone I was impressed by both the depth of his knowledge of financial crime and his ability to work with all parts of an organisation. He has rare balance of technical knowledge and pragmatism.
Read MoreGroup Head of Financial Crime Compliance at Brooks Macdonald Group
Aaron Guilder
Group Head of Financial Crime Compliance at Brooks Macdonald Group
We have worked with Tyrone on a number of our AML/ Financial Crime projects over the last few years and he is a practical, knowledgeable colleague with a strong customer focus who we enjoy working with.
Read MoreExecutive Director - The Compliance Foundation
We have worked with FinCrime Protection Ltd on a number of our AML/ Financial Crime projects over the last few years and he is a practical, knowledgeable colleague with a strong customer focus who we enjoy working with.
Sandra Quinn
Executive Director - The Compliance Foundation