Financial crime rules are getting tougher, and the risks are getting smarter. Between tighter FCA scrutiny and evolving threats like fraud, money laundering, and sanctions evasion, firms are under constant pressure to prove their systems can stand up to real-world challenges.
The question is – how do you know your financial crime framework is actually doing its job?
Regular, honest assessments aren’t just another compliance task. They’re a critical safeguard for your firm, your clients, and your reputation – and the best way to spot weaknesses before the regulators (or bad actors) do.
Why Regular Programme Assessments Matter
Financial crime does not stand still and neither should your response. Regulators expect firms to take a risk-based, proportionate and proactive approach to financial crime prevention, backed up by regular internal reviews. These reviews are not just about satisfying the FCA; they’re about spotting gaps, fixing inefficiencies, and staying ahead of evolving risks.
An effective assessment process helps you:
- Understand your current level of compliance
- Identify weaknesses in controls or procedures
- Prioritise actions based on risk exposure
- Demonstrate a culture of compliance and accountability, not just a checklist
Key Elements of a Strong Financial Crime Programme Review
A proper review means looking at every aspect of your financial crime framework – from governance at the top to how alerts are handled day-to-day. Here’s what to focus on:
1. Governance and Oversight
Are senior management and the board actively engaged in financial crime oversight? The FCA expects clear accountability, strong governance, and proof that senior leaders are actively engaging with – and challenging — the risks.
2. Policies and Procedures
Are your policies up to date with the latest regulatory expectations, including sanctions regimes, anti-bribery laws and AML rules? Regular reviews ensure they remain relevant and aligned with your firm’s risk profile.
3. Customer Due Diligence (CDD)
Does your onboarding and monitoring process capture the full risk profile of your clients? High-risk customers must be identified early and subjected to Enhanced Due Diligence (EDD) where appropriate.
4. Transaction Monitoring
Are your systems and controls capturing suspicious activity effectively? Consider whether your alerts are timely, relevant and proportionate to the risks your firm faces.
5. Staff Training
Is your team equipped to recognise and respond to financial crime risks? Ongoing, role-specific training is essential for embedding a culture of compliance across the firm.
6. Reporting and Escalation
Are there clear protocols for internal escalation and external reporting (e.g. Suspicious Activity Reports)? FCA expects firms to respond promptly and responsibly to potential threats.
Common Weak Spots Firms Encounter
Through our work with regulated firms, we often see recurring challenges:
- Reliance on outdated or manual systems
- Inconsistent application of CDD and EDD
- Gaps in sanctions screening or PEP identification
- Lack of clear MI and reporting lines to senior management
- Training that is too generic or not regularly updated
Recognising these challenges is the first step to improving.
The Regulator’s Expectations Are Clear
Financial crime remains high on the FCA’s supervisory agenda. Recent reviews and enforcement cases make one thing obvious – meeting the bare minimum isn’t enough.
The FCA expects to see:
- Risk assessments are not just paper exercises
- Technology is used effectively (not just implemented)
- Management information is used to drive decisions
- Controls are reviewed and adapted regularly
A strong financial crime framework is never “done”, it evolves in line with your business model, client base and the broader threat landscape.
How ComplyPortal Supports Your Review
At ComplyPortal, we work with firms to simplify the process of assessing and improving their financial crime systems.
Our platform enables you to:
- Conduct structured Financial Crime Risk Assessments
- Automate record-keeping and audit trails for CDD/EDD
- Assign and monitor mandatory compliance tasks
- Track issues, remedial actions and outcomes
- Ensure policies and registers are version-controlled and easily accessible
Our tools and oversight dashboards give you a clear view of what’s happening, so your team can spend less time on admin and more time on the work that really protects your firm.
Final Thoughts
In today’s regulatory climate, financial crime is not just a compliance issue, it is a reputational and strategic risk. Regularly reviewing and improving your financial crime programme is essential to staying ahead of threats and demonstrating regulatory alignment.
Whether you are a small firm looking to strengthen your controls, or a larger firm preparing for a regulatory visit, starting with a clear assessment is key.
Ready to assess the strength of your financial crime programme?
Book a short, no-obligation demo to see how ComplyPortal can support your team in streamlining reviews, improving oversight and reducing risk.
