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.


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