Operational Risk Management And Money Laundering
OBJECTIVE:
A strategic review of this area should consider the current and likely future business activities relative to a sound operational risk methodology compared to the internationally accepted customs and practice.
APPROACH
- Corporate Governance (from discussions & review)
- Composition of Board, non-executive directors, committees (e.g. remuneration, audit). Adequacy of polices & procedures
- Branch network, management & reporting. Consideration of risks surrounding the branch network, especially any branches operating in other countries.
- Regulatory framework: Reports from external/internal auditors
- Existence of a formal risk management process tailored to business objectives and its principles embedded throughout the organisation
- HR vetting of new staff & placements to management positions
- Internal Audit
- Review of reports etc
- Relationship with Audit Committee and consideration of independence & objectivity
- Workshops to establish key risk areas & expertise/experience of the division
- Review of the reporting mechanism to see if extra value could be added
- Culture
- Culture review to assess key components, especially front office/back office split and whether any personal fiefdoms (ie divisions run by powerful managers who, by reputation or personality, operates outside normal control procedures)
- Assessment of controls, especially how robust they are under pressure and whether they are subject to management override
- Specific risk areas
- Money laundering. Consideration of procedures against legal requirements/ Financial Action Task Force recommendations. Awareness of the risks by all appropriate staff. Suspicious transaction reporting.
- Fraud
- Best practice C Anti-Fraud policies and procedures and Modern detection techniques


