Financial Institutions risk-based AML/CTF programmes are designed around a comprehensive risk assessment, based on a decade old model focused on compliance risk which, in turn, acts as a proxy for financial crime risk. This model is becoming less fit for purpose as National Risk Assessments identify specific threats and National Priorities begin to direct enhanced action against these particular threats. It is also potentially ill suited for financial institutions (FIs) with smaller and less complex businesses who may lack dedicated risk assessment teams.

Today FIs find themselves exposed to a more diverse and complicated set of criminal threats, with the threat landscape continuing to evolve as criminal activities proliferate and money laundering techniques expand. 

That’s why Financial Crime News partnered with Mox a Hong Kong based digital bank (part of the Stan Chart Family) and Oliver Wyman to pilot a new approach taking FCN’s comprehensive Country Threat Assessment on Hong Kong and applying it to MOX’s business and through OW and MOX’s FCC Teams generating inherent risk and controls effectiveness views that focus on specific financial crime risks. We are sharing our work to encourage the adoption of adding the threat view into AML/CTF Risk Assessments. For more information including access to Threat Assessments already available on countries such as Austria, Australia, France, Germany, Hong Kong, Ireland, Italy Russia, Spain UK and the UAE (with more to follow this year) as well as 14 leading Sub Saharan African Countries, please see the FCN a homepage or contact me directly.