Review of high risk client base

Financial Crime Projects

Review of high risk client base


A leading UK bank asked Campion Willcocks specialists to review their high-risk client base and then establish a BAU unit to oversee ongoing monitoring of the population.


The Campion Willcocks team designed and delivered an end-to-end operating model for the review of the high-risk population. The team reviewed approximately 17,000 EDD files and implemented an extensive customer contact programme. Campion Willcocks also managed the exit process for non-responding customers and those who fell outside the client’s risk appetite. As part of the solution, Campion Willcocks built a bespoke workflow management information system.


The high risk population was fully reviewed within the estimated timeframe. Campion Willcocks transitioned the ongoing monitoring into a standalone BAU unit with more than 80 FTE personnel to oversee the population going forwards.

Why CW Compliance?

The bank was aware of Campion Willcocks’ reputation and expertise in conducting remediation and compliance work for clients worldwide.