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
Fraud contingency plan and practical tips for investigators. Lessons from headline cases
Summary Basel II.pdf