CFW Fin Crime Consulting

Our services

Our services act as an extra
pair of hands

You can think of us as an extension of you and your team, supporting you with strategic financial crime initiatives as well as responding to regulatory intervention.

At CFW, our focus is on providing you with structured, pragmatic and personal support.

What does this actually mean in practice?

Structured - there's no bull-in-a-China-shop mentality here. We invest time to understand you, your unique situation and challenges, and your goals and objectives. We want to understand where you've been, where you're at, and where you're going to so that we can provide an organised and logical service which is tailored and bespoke to you.

Pragmatic - we bring years of real-world, lived experiences gained from working alongside financial crime leaders at a diverse range of institutions, as well as working on behalf of regulators like the FCA. This uniquely positions us to provide proportionate and thought-through advice which is appropriate based on your size, scale and complexity.

Personal - we value a human touch. We'll never recite regulation at you, bombard you with technical jargon or go AWOL without warning. Rather, we'll collaborate with you in a flexible and collegiate manner to provide you with specific, tailored support at the time(s) when you need it.

Our current services include the following types of support:

1 - Lot E s166 Skilled Person review firm-side support

Who is this for?

MLROs/Chief Compliance Officers/Heads of Compliance who are entering into a Lot E (Financial Crime) s166 Skilled Person Review with the FCA.

How can CFW Fin Crime Consulting support?

Interpreting and critically evaluating the Draft Requirements Notice
Liaison with the FCA regarding scope, timelines, approach etc as captured in the Draft Requirements Notice
Support in evaluating Skilled Person firm proposals and choosing the right one to appoint given your specific situation and needs
Liaison with the appointed Skilled Person team for administrative aspects of the review (such as diarising walkthroughs and interviews, project management for responding to Requests for Information)
Drafting orientation material to support the mobilisation and smooth running of the Skilled Person review, such as mobilisation packs
Preparing you and your team(s) for the practical elements of a Skilled Person review which may feel daunting, such as conducting mock interviews
Triaging/QA-ing material before it is shared with the Skilled Person team to validate that it adequately covers the Requests for Information and does not contain any content which the Skilled Person team might consider adverse
Undertaking an additional 4-eyes check of the Skilled Person's report for factual accuracy and proportionality

2 - Assurance

Who is this for?

MLROs/Chief Compliance Officers/Heads of Compliance who require an independent and objective review undertaken by an experienced, SME practitioner.

How can CFW Fin Crime Consulting support?

AML/Financial Crime 'audit' to provide independent assurance on both the design and operating effectiveness of your financial crime framework, or discrete parts of it, to give comfort to banking partners or wider external parties that your financial crime framework has been designed and is operated in a manner which aligns to regulatory requirements and expectations
VREQ-lifting pre-audit - objective review of the functional operation of newly uplifted/created financial crime controls to validate that they are being performed in line with your own internal policies and procedures and in a manner which would stand up to regulatory scrutiny
Validation that 2LoD Compliance Monitoring and/or 3LoD Internal Audit findings have been adequately closed/remediated

3 - Financial crime project management

Who is this for?

1LoD or 2LoD Financial Crime leaders who require an experienced SME practitioner to support with financial crime programme mobilisation and/or delivery, as well as provide technical input.

How can CFW Fin Crime Consulting support?

Defining/shaping the project/programme in terms of input into phasing, workstreams, action plans, milestones, critical pathway and key deliverables)
Taking ownership and accountability for
- - Defining/shaping the RACI matrix
  - Proactive project/programme risk managenent (including production, maintenance of and presenting of RAID logs)
  - Engaging with stakeholders across the business to secure buy-in, retrieve data/inputs, liaison regarding status updates etc
  - Internal reporting protocols (such as production, maintenance of and presenting of MI/dashboards etc)
Managing a team of analysts/other SMEs from project/programme inception through to delivery and completion
Supporting internal Financial Crime leaders with external reporting and regulatory liaison

4 - Framework enhancement

Who is this for?

1LoD or 2LoD Financial Crime leaders who require an experienced SME practitioner to help design/enhance the financial crime control framework with minimal oversight and supervision and maximum proactivity and autonomy.

How can CFW Fin Crime Consulting support?

Uplift of core financial crime policies/procedures to align to regulatory requirements and expectations and stand up to regulatory scrutiny
Collaborative design of new financial crime controls, such as a proportionate and risk-based Compliance Monitoring Plan, Risk Appetite Statement thresholds and metrics, BWRA
Creation of discrete financial crime governance and oversight materials such as training packs, MI dashboards etc

Coming Soon Interim MLRO support

Who is this for?

Firms whose C-suite/ExCo/Board are looking for a capable and experienced financial crime senior leader on an interim and/or part-time basis to drive the 2LoD Financial Crime strategy forwards, enabling other existing staff to continue with BAU roles and responsibilities.

How can CFW Fin Crime Consulting support?

Acting in an interim MLRO capacity for 1-2 days per week to support EMI/PI licence application
Providing oversight for other team members executing BAU tasks (such as onboarding, TM alert investigation, Screening alert investigation etc)

Our commitment and promise to you

At CFW, we will:

✔️ Deliver practical advice and guidance which is rooted in our deep understanding of regulatory requirements and expectations. This is gained from a decade and a half of working with regulated institutions as well as regulators like the FCA.

✔️ Collaborate with you and your teams to identify the right solution(s) based on understanding your unique situation and needs. This means we listen, diagnose and suggest rather than coming straight in with a solution to a problem you may not have.

✔️ Put forward transparent and fair contractual arrangements. Our standardised Terms of Business and Engagement Letter ensure you have complete clarity on exactly what you're getting and when.

✔️ Provide proactive and clear communications and updates to enable you to understand work progress and next steps. We do this to manage your expectations, and also help you to communicate with other key internal stakeholders.

✔️ Work with you in a flexible and adaptable manner. You don't need us 5 days a week every week but need a more streamlined arrangement? Fine. You don't work on a particular week day but you still need work to progress/get done in your absence? No problem.

At CFW, we won't:

❌ Overpromise and underdeliver. We strictly adopt an open and transparent approach from day 1 to make sure you and we are clear on what we can deliver, when and to what level of detail so there are no surprises.

❌ Deliver committed work using unskilled, inexperienced resources. You will always get Clarinda - if she is not available or does not have the requisite specialism to perform the work which you need, she will help connect you with trusted members of her network who can.

❌ Provide generic, AI-generated output which doesn't add value to you or account for your specific situation and needs. We leverage tools and technology to enhance efficiency, but our guidance and support is always grounded in our extensive experience and subject matter expertise.

❌ Propose a low initial commercial offer to get a foot in the door, but then surprise you with unexpected/unreasonable add-ons once contracts have been signed.

❌ Go AWOL. Our pet peeve is consultants who commit to work but then are hard to get hold of. We'll always be up-front with you about our availability, and we'll work with you around things known like annual leave to ensure that progress doesn't come to a stand-still.

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