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.
Inside you will find
- 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.
Structured to be useful, not to impress.
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
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