Developing a risk framework to combat financial crime
The brief
A global online travel and tourism group wanted to design and implement a globally consistent Sanctions Risk Management Framework. The client’s sector focus meant that the jurisdiction-specific control design was particularly sensitive due to added reputational and regulatory pressures.
Our approach
Companies in the group are located all around the world, so defining a set of global requirements and policies required engagement with a large number of internal and external stakeholders.
Our team conducted the following activities:
- Facilitated discussions with external counsel in the US and EU to determine the sanctions list screening requirements;
- Engaged with technology solution providers to determine the most effective and efficient configuration of sanctions screening tools;
- Proposed new country risk rating methodology and documented formalised processes;
- Developed an industry-leading approach to governance, including RACI, process and policy documentation as well as key sanctions KRI/KPI definition for 3LOD Model.
The solution and key benefits
There were several key outcomes of the project, including a globally consistent approach across the group to sanctions screening, jurisdiction specific requirements (including full blocks on sanctioned territories and other reputationally sensitive areas) and a suite of documentation providing a more effective governance model. This provided the client with a more robust risk framework to combat financial crime.
