Executive summary

A risk-based design for anti-money laundering, sanctions and anti-bribery compliance that a supervisor can test.

What is inside

What the programme design covers

The asset confirms obligations, assesses business-wide risk, sets customer risk ratings and review cycles, designs and calibrates monitoring and screening, sizes operations and sets assurance and board reporting.

  • Obligations register by jurisdiction
  • Business-wide risk assessment
  • Customer risk rating and review cycles
  • Monitoring and screening design
  • Calibration with below-threshold testing
  • Capacity model for alert operations
  • Assurance, board reporting and the review record