Campion Willcocks was asked to work with a multi-jurisdictional bank to re-design their financial crime target operating model, including providing a suite of new standards and procedures, and then to assist in the implementation.


Campion Willcocks worked with senior stakeholders to build a new three lines of defence model, based on industry best practice, and undertook a wide consultation process across the business to ensure buy-in. Once the model was approved, Campion Willcocks then created the standards and procedures to sit within the framework, ensuring for the first time that the bank had a consistent approach to financial crime across their jurisdictions.


The client’s Board approved all the proposed target operating model, standards and procedures, and a 12-month programme to implement the new framework was successfully executed. The client now has a framework, which meets their regulators expectations.

Why CW Compliance

We have deep experience in advising clients on their financial crime target operating models and drafting simple and easy to use policies and procedures.