Board Oversight of Financial Crime
A practitioner's account of what good Board oversight of financial crime actually looks like, month by month.
For Non-Executive Directors, Audit and Risk Committee chairs, MLROs and Heads of Compliance.
Guide 005 sets out, month by month, what good Board oversight of financial crime looks like in practice. It covers the four decisions the Board cannot delegate, how to read the MLRO report and the MI pack, how to receive the annual opinion, how to hold the second line accountable, the Board's role during remediation, MLRO succession and how to record the discussion in a way that a supervisor will recognise three years later. It closes with the Board's twelve-month calendar and a working speaker brief for the MLRO presenting the annual opinion.
Dentro encontrará
- The four decisions the Board owns: appetite, capacity, escalation, assurance
- Reading the MLRO report, the MI pack and the regulatory correspondence
- Receiving the annual MLRO opinion and holding the second line accountable
- The Board's role during remediation and MLRO succession
- Recording the discussion: minutes that hold up under supervisory review
- Appendix: the Board's twelve-month financial crime calendar and a working speaker brief for the MLRO
This is the guide I would hand to a Non-Executive Director the week before they chair their first financial crime discussion, and to an MLRO the week before they brief one. It is not a primer on the regulation. It describes the work the Board actually does: the papers it reads, the questions it asks, the decisions it owns and the conversations that distinguish oversight from acknowledgement.
Fourteen sections, in the working order of a Board year. The first four cover the cycle and the papers. The middle six cover the discussions that move the needle. The last four cover the moments that matter most: receiving the annual opinion, hearing from the regulator, holding the second line accountable, and recording the discussion in a way that a supervisor will recognise.
Estructurado para ser útil, no para impresionar.
The four decisions the Board owns: appetite, capacity, escalation, assurance
Reading the MLRO report, the MI pack and the regulatory correspondence
Receiving the annual MLRO opinion and holding the second line accountable
The Board's role during remediation and MLRO succession
Recording the discussion: minutes that hold up under supervisory review
Appendix: the Board's twelve-month financial crime calendar and a working speaker brief for the MLRO
10 Questions Every Board Should Ask Before the Regulator Does
Ten Board-level governance questions, with a structured self-assessment and score guide.
Ver guíaIs Your AML Remediation Programme Set Up to Succeed?
Nine sections covering governance, quality assurance, MI, Board reporting and root cause analysis.
Ver guíaPreparing for an AML Inspection
Eight focus areas from governance and CDD through to evidence preparation, with a readiness score.
Ver guíaManaging an AML Remediation Programme
Fourteen working sections covering scope, governance, prioritisation, QA, MI, Board reporting and close-out.
Ver guíaPreparing for an AML Inspection
Fourteen working sections covering the notice letter, the document request, the data room, the interviews, the exit meeting and how to respond to draft findings without negotiating away the truth.
Ver guíaQuality Assurance During KYC Remediation
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.
Ver guíaBuilding Meaningful AML Management Information
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.
Ver guíaScoping an AML Remediation Programme
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.
Ver guíaSi no está seguro de si su organización se beneficiaría de apoyo externo, hablemos.
Si no creemos que Claritas sea la opción adecuada para su organización, se lo diremos con franqueza.