With regulator increasing scrutiny on financial crime controls, how does your firm measure up? 

In an effort to provide a better experience for consumers, we often see a desire to make the client onboarding process as quick and easy as possible for the end user. However, this also seems to be attracting the attention of criminals—specifically those who intend to set up “money mule networks”.

To capture potential customer interest, financial firms and banks may promote their quick and efficient onboarding process. The ability to open accounts easily and within minutes might make procedures of the traditional high street bank seem draconian in comparison. However, is it equally draconian to consider that with increased speed comes increased scope for error?

As an example of increased FCA scrutiny, the FCA recently reviewed a sample of challenger banks to obtain a clearer picture of how these institutions are exposed to financial crime risk—especially money laundering. Their analysis was focused on (but not limited to) the following financial crime procedures within the firms reviewed:

  • Governance and management information
  • Policies and procedures
  • Risk assessments
  • Identification of high risk / sanctioned individuals or entities
  • Due diligence and ongoing monitoring
  • Communication, training, and awareness


Changing and updating processes in the name of progress is a valid and noble idea, but not when that change leads to wider scope for abuse by the criminal fraternity and increased and unnecessary exposure to risk for the consumer in general—particularly those that are more vulnerable than others.

Through this review, the regulator concluded that, although challenger banks rely on fast customer growth in order to expand, this does not mean that they must sacrifice their compliance with Customer Due Diligence (CDD) obligations as set out within the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLRs) (as amended).

It would appear the regulator seems to be acknowledging the success and advantages that the challenger banks provide, whilst on the other hand requiring their financial crime frameworks to mirror the more traditional model. The ideal approach appears to be one that can offer a hybrid model of speed, agility, and tradition.

How ComplyPortal can help

Regtech and compliance management technology offer compliance officers tools to balance the many demands of demonstrating control of compliance responsibilities. For example, ComplyPortal’s Monitoring module helps to continuously monitor tasks while producing a full reporting and audit trail to demonstrate continuous monitoring to the regulator.

Additionally, tools like the visual ‘heatmap’ in ComplyPortal’s Risk module help firms to map risks and track both inherent and residual risk scores which could impact their firm’s financial crime procedures. This allows firms to easily visualise and focus on those controls which are most important at mitigation of highest risk areas.

Compliance teams can also ensure staff awareness of company procedures through ComplyPortal’s Attestations module. Users can efficiently send reminders for staff to affirm their understanding of policies and procedures and how they can contribute to minimising financial crime risks throughout a firm.

Using software to assist and centralise areas of compliance gives compliance officers more time and freedom for complex tasks like long-term strategizing and planning for current and future operational risks.

Find out more about how the ComplyPortal platform can help firms adapt to new regulatory expectations at: https://complyportal.uk/modules

About ComplyPortal:

First developed in 2011 by compliance professionals for compliance officers, ComplyPortal offers workflow, automation, and several modules to help firms with control and regulatory compliance monitoring.

ComplyPortal simplifies financial services regulatory compliance management on an easy-to-use cloud-based comprehensive compliance platform. It enables compliance officers, risk officers and senior management to keep track of their firm’s regulatory responsibilities and workflows. Our platform includes the following modules, among others:

  • Monitoring: a year-round schedule pre-populated with monitoring questionnaires to ease compliance processes.
  • Registers: lists controlled by the Compliance officer, but easy for staff to view.
  • Risk: map and control risk areas to effectively identify and manage risk for your firm.
  • eKYC solution: perform comprehensive searches, including client identity verification, document authenticity, and more for a comprehensive KYC and AML approach