Change & Transformation

Enhancing your Financial Crime Framework

A risk-based financial crime framework is a necessary foundation for regulated financial services firms to meet their obligations. Ensuring a robust framework prevents unwanted regulatory scrutiny, reputational damage and protects your institution and customers from financial crime.

Our experts have designed financial crime frameworks and built suites of financial crime policies and procedures for a portfolio of global clients.

Amongst a wide array of areas, our Subject Matter Experts have designed frameworks in the following:




Anti-Bribery and Corruption

Anti-Tax Evasion

Controls Testing

Our extensive experience in undertaking gap analysis of existing policies and procedures against global regulations has helped clients identify and subsequently mitigate risks. We can assist in the design and application of new frameworks to ensure and demonstrate wide-spread implementation and adherence across the organisation, whilst minimising the impact on commercial activity and BAU resource. 

What CW Compliance can do for your business

Framework Enhancement

We lead and manage group-wide consultations on target operating models (TOM) suitably matched to your organisation’s risk appetite and objectives, as well as the development of financial crime policies and procedures; Overseeing the embedding of newly designed operating frameworks and ensuring sustainability, appropriate governance and alignment of responsibility (RACI)

Operational Enhancement

Our expertise includes developing group-wide desktop processes, compliance procedures, first line and second line operational toolkits

Continuous Improvement

We implement structured feedback loops for continuous improvement

Stakeholder Engagement

We communicate clearly and succinctly with senior stakeholders, including progress reporting and presenting to C-suite level personnel

Process Flow

We restructure specific process flows, mapping current processes and redesign the target state process

Regulatory Reviews

Our experts constructively engage with regulatory requests as part of thematic reviews

Risk Appetite Statement

Our experts constructively engage with regulatory requests as part of thematic reviews

Business Wide Risk Assessment

We undertake thorough reviews assessing a business’s risks and effectiveness of their mitigation framework

Training and Development

Our Subject Matter Experts deliver targeted training to help teams adapt to new processes, procedures and technologies

Our Comprehensive Approach to improving Financial Crime Frameworks

Our approach involves a multifaceted strategy, which chiefly focuses on strengthening governance structures and emphasises the importance of proactive compliance culture. We conduct thorough risk assessments, implement risk mitigation strategies and assess the overall effectiveness of the financial crime framework. By executing a holistic and adaptive approach, we help clients develop a robust financial crime framework.

Case Studies

Design and build new three lines of defence model

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.

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New suite of financial crime procedures

Campion Willcocks was asked to review and enhance the financial crime procedures of a medium-sized South African Bank.

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