Moneta●
TRAINING IDEAS
MODULES
FCRM Masterclass
Looks at FCRM through the lens of leaders and first line bankers who are directly responsible for agreeing risk appetite, business strategy and parameters and/or managing client facing businesses or individual clients. Equally applicable and valuable though for those in supporting/wider risk management roles.
The last 10 years has been a period of increasingly intense focus by financial regulators everywhere scrutinising banks’ ability to identify and manage financial crime risk. Intervention by US and Western European regulators has been especially intense. With fines to date in excess USD40bn and subsequent remediation and transformation budgets a multiple of this, banks globally have had to accept the need and importance of better controls to identify, measure and manage the financial crime risk in their business.
Course outline
Module:
1
Pride and Prejudice – defining financial crime and trends
Defining Financial Crime
Development of economic crime,
Trends in regulatory intervention
How banks and bankers have been caught up in it
What have been the common failures
What have been the consequences of censure.
Case Study: Learning points from HSBC, Goldman, Credit Agricole, Deutsche, Swedbank.
Module:
3
Risky Business - if you can’t measure it, you can’t manage it!
The importance of risk measurement and prioritisation.
Risk based control frameworks, remediation and measurement techniques
Considerations in establishing risk appetite
Why understanding risk is the prerequisite
Why banks remediate and waste money without a foundational knowledge of risk.
Typical issues in risk measurement.
Case study: Examples of the economic and opportunity cost of ignorance.
Module:
5
Minority Report - Weaknesses in existing (and new) control models
Towards a Trigger event utility.
A look to the future
Intelligence lead FCRM
Public Private Partnership
Case study: the controllers and minority interests. Real risk factors. Consider false positives and the cost of discounting. And how tech including AI and Robotics can focus on them.
Module:
7
Cape Fear - Have banks gone too far?
What’s the economic and social cost of “the new reality”.
How do we know “when we are done”?
The importance of confidence
Case Study: Is a high-risk client a bad client? What’s the cost of withdrawal? Who is taking up the slack?
Module:
2
An Inspector Came to Call - what to expect from the regulators
Identifying the unknown unknowns
Regulatory interview role-play with questions drawn from a bank of real scenarios from US and UK regulators
Module:
4
The Towering Inferno – It’s not all about KYC!
Key foundations of a control framework/operating model to manage financial crime risk
Roles and responsibilities of first, second and third line.
Risk Appetite definition and risk measurement.
Best practice in Client Due Diligence[CDD]
Importance of data integrit
Transaction Monitoring and Screening
Quality Assessment.
Culture
Governance and Assurance
Case Study: The value chain. Combining the above to form a strong control chain and the risks of failure to address or complete any link
Module:
6
Atonement -The critical role of Culture
An overview of cultural issues in banking and problems in resolving them.
Risk vs reward
What does good look like? In Leaders in bankers?
How do you prove it?
The sacrificial lamb
Case Study: Building sustainablechangesin awareness, capabilities and behaviours
Case study: The role of education, incentivisation, performance managementand validation.
Module:
8
The Panic Room – How to Manage Regulatory Intervention
What can go wrong? - Examples of 'bad management' of regulatory intervention
Turning a drama into a crisis - consequences of 'bad management'
The nature of regulatory intervention
Section 166
Control orders
Cease and desist orders
MRA’s, MRIA’s (Issues requiring management attention or immediate attention)
What is best practice?
How to address the intervention?
What regulators typically expect?
Management of expectations
Delivery versus under delivery
Working towards closure