Review and evaluate the implementation of your organisation’s countering financial crime policy

This standard is about reviewing and evaluating the implementation of your organisations countering financial crime policy. You must be able to take a strategic view on the overall implementation of your organisations countering financial crime policy. This involves ensuring that policies and procedures and systems and controls are monitored and reviewed to identify weaknesses and to understand why failures occur. You must be able to recommend actions to remedy ineffective controls and report your findings in the appropriate manner. You will ensure that adequate reporting channels exist in communicating recommendations for improvements to controls and that clear procedures are in place and communicated across the organisation. This standard is relevant to roles in countering financial crime.

1. Check that the policy was clearly communicated across the organisation.
2. Analyse the compliance of the organisation against the financial crime policy.
3. Review the conduct of your organisation in countering financial crime, referencing good practice in terms of ethical, moral, and lawful behaviour.
4. Confirm that the policies and procedures reflect the values of the organisation and its approach for countering financial crime.
5. Review the impact that countering financial crime policies and procedures have on each area of your organisation.
6. Review the resources required for the continued implementation of countering financial crime policy to ensure that it is sustainable.
7. Recommend areas for change or improvement in countering financial crime policy where they are identified as necessary.
8. Report to those responsible for implementing the actions needed for improvement.
9. Confirm that actions for improvement have been carried out.
10. Communicate any changes to the policy across the organisation.
11. Monitor the effectiveness of any changes made and adjust as necessary.

1. Your organisation’s strategy and approach towards countering financial crime.
2. How your organisation defines financial crime in order to evaluate appropriate policies and procedures and systems and controls.
3. How to develop evaluation measures and criteria.
4. The information that is required to inform your evaluation of the countering financial crime policy and where this can be obtained.
5. How to determine if you have sufficient information and evidence to evaluate countering financial crime policy.
6. How to analyse the information and evidence to assess the effectiveness of the countering financial crime policy.
7. How to identify any actions needed to improve the effectiveness of the procedures, systems, and controls underpinning the countering financial crime policy.
8. How to escalate the findings of your evaluation.
9. The procedures and methods for checking that changes and improvements have been implemented and the actions to take if they haven’t.
10. The systems and processes for continual review and improvement.
11. The legislation, regulations, and codes of practice, relevant to you and your organisation and any specific obligations.

"Financial Crime
This includes any office involving money laundering, terrorist financing, fraud
or dishonest or market abuse. (Definition based on the FCA definition of
financial crime). This includes financial crime both internal and external to a
financial services organisation.
Legal and regulatory requirements
This refers to a range of obligations incumbent upon financial organisations
and is commonly referred to as ‘compliance requirements. The legal and
regulatory requirements of an organisations or individual/s within it (such as
‘approved persons) may differ slightly according to the type of financial
organisation and the services it offers. The regulator of all providers of
financial services in the UK oversees a number of regulated activities under
powers derived from the Financial Services and Markets Act 2000.
A number of other pieces of UK legislation are relevant to the countering of
financial crime, such as the Proceeds of Crime Act (POCA), the Serious
Organised Crime and Police Act (SOCPA, the Fraud Act 2006, for example.
UK financial institutions are also subject to European Commission legislation
enacted by the British Government such as the Market Abuse Directive and
the Basel 2 Accord (for capital adequacy).
Financial organisations, like any other employer, are also subject to a range of
legal requirements covering areas such as discrimination, equality and
diversity, Health and safety and Data protection.
Systems and controls
The practices and procedures put in place to protect an organisation from
financial crime. In some cases it is accepted that certain (or indeed all) types
of financial crime cannot be wholly prevented, but controls can limit its extend
and impact."