Análisis independiente sobre gobernanza AML, evolución regulatoria y expectativas supervisoras en Europa, escrito para Consejos, MLROs y alta dirección.
Nuestras Perspectivas son piezas editoriales extensas y, por ahora, se publican en inglés. Las traducciones cuidadas al español llegarán en próximas ediciones.
Marcos descargables, listas de verificación y guía práctica diseñados para ayudar a Consejos, MLROs y equipos de Cumplimiento a reforzar la gobernanza, prepararse ante el escrutinio regulatorio y gestionar el riesgo de delitos financieros.
Fourteen working sections covering population definition, segmentation, the file standard, productivity pilots, capacity in layers, governance, mobilisation, dependencies, budget, contingency and the assumptions register that holds the plan together.
28 min read · PDF
Fourteen working sections covering the three lenses of activity, quality and residual risk, the five-question rebuild, KRIs and thresholds, the commentary discipline, escalation, the annual rebuild and how MI fails quietly.
26 min read · PDF
Fourteen working sections covering sample design, defect taxonomy, calibration meetings, trend reporting, re-review triggers, acceptance criteria and how QA supports governance rather than only measuring it.
26 min read · PDF
Las Perspectivas Regulatorias de Claritas forman una serie estructurada que explora la gobernanza AML, la supervisión y el riesgo de delitos financieros. Empiece por la Introducción para tener una visión completa, o explore directamente el tema más relevante para su entidad.
Supervisory focus has moved beyond policies to the evidence that governance, accountability and controls operate in practice.
Simple questions that move a board conversation from policy compliance to genuine oversight.
Policy reviews have value. But they rarely test whether controls operate in practice. Independent challenge brings a different lens.
Governance is no longer assessed by organisation charts. Regulators want evidence of informed discussion, clear accountability and constructive challenge.
The firms that perform well during inspections are rarely those making last-minute changes. They are the ones that prepared earlier.
A readiness assessment is not another report. It answers one question: if a regulator reviewed the framework tomorrow, how confident would we be?
Supervisory findings rarely stem from missing policies. They stem from the gap between what a policy says should happen and what happens in practice.
Most of the work firms need to do has very little to do with the remaining technical standards. Strengthening governance, CDD and management information takes time.
Most firms spend their time looking for new financial crime risks. Fewer stop to ask whether yesterday's customers still represent today's risks.
Financial crime reporting has improved. The challenge for many Boards is no longer obtaining information, it is whether that information supports better decisions.
Remediation programmes rarely fail because one document is missing from one file. They fail because governance is unclear, quality is inconsistent and management information measures activity rather than risk.
Programmes do not drift in month six. They drift in the first ninety minutes, when the scope is described loosely, the volumes are estimated optimistically, and nobody insists on writing down the definition of a completed file.
Boards rarely ask the MLRO what would make their job easier. The answers tend to be specific in a way the formal papers never are, and acting on one or two of them, year on year, is the difference between supporting an MLRO in name and in practice.
What people say about their controls and what their files actually show are almost never identical. Better the firm finds the gap than the inspector does, and better the firm names it openly than tries to edit it away.
Put the same file in front of five experienced reviewers. If they disagree on whether the analyst's decision was right, the analyst is not the issue. The framework against which everyone is working is the issue, and the framework is fixable.
The decisions the Board took that were not connected to any specific page in the pack are the map. They tell you which numbers the Board actually needed to see and was not being shown. They are almost always residual risk numbers.
I have been asked, more than once, to recover programmes described as 'too ambitious'. That has almost never been the problem. The problem, in every case, was that the ambition had been priced against assumptions nobody had tested.
