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Financial Crime Risk Assessment: The Foundations for an Effective Financial Crime Program

In the ever-evolving landscape of global finance, the spectre of financial crime looms large, presenting a multifaceted challenge to institutions, governments, and businesses alike. Financial crime encompasses a broad spectrum of illegal activities, including money laundering, terrorist financing, fraud, and cybercrime, all of which can undermine the stability and integrity of financial systems, erode public trust, and inflict significant economic damage. Against this backdrop, financial crime risk assessments emerge as a critical tool in the arsenal of organisations seeking to combat these illicit activities, ensure regulatory compliance, and safeguard their businesses.

The Importance of Financial Crime Risk Assessments

Financial crime risk assessments are vital for several reasons. Firstly, they enable organisations to identify and assess the specific vulnerabilities within their operations that could be exploited for financial crime. By evaluating factors such as the nature of their business, customer base, transaction volumes, and geographical presence, organisations can identify high-risk areas that require enhanced controls and oversight.

Secondly, these assessments are a cornerstone of regulatory compliance efforts. Regulatory bodies around the world and standard setters including the Financial Action Task Force (FATF), mandate that financial institutions undertake regular and comprehensive assessments of their exposure to financial crime risks. Compliance with these regulations not only helps in preventing financial crime but also protects organisations from potentially severe penalties, including fines, sanctions, and reputational damage.

Typical Approaches To Completing the Assessment

Conducting a financial crime risk assessment typically involves several key steps:

  1. Identifying and Categorising Risks: This involves outlining the types of financial crimes that could impact the organization, considering factors like industry sector, customer profiles, and transaction types.
  2. Inherent Risk Evaluation and Scoring: Organisations assess the likelihood and potential impact of identified risks, often using scoring systems to prioritise areas of concern.
  3. Control Measures Review: Assessing the effectiveness of existing controls and procedures in mitigating identified risks.
  4. Residual Risk and Gap Analysis: Assessment of the residual risk against the desired level of risk mitigation.
  5. Action Plan Development: Creating strategies to address identified gaps, which may include implementing new controls, enhancing existing procedures and systems, or conducting further training.

Regulatory Expectations

Regulators expect financial institutions to adopt a comprehensive, risk-based approach to combating financial crime. This includes conducting risk assessments that are thorough, up-to-date, and reflective of the organisation's current risk exposure. Regulatory bodies also expect organisations to demonstrate a clear understanding of their risk profile and allocate resources proportionately to higher-risk areas.

Common Challenges and Pitfalls

Traditional Risk Assessments can become overly complex, are often highly manual, and can take many months to complete. The result is they can become outdated before they are even finished. 

The common pitfalls in financial crime risk assessments include:

  1. Adoption of generalised risk assessments that do not adequately reflect the organisation, its products, customers, and the geographies within which it operates.
  2. Lack of specificity in the inherent risks included within the assessment.
  3. Lack of defined methodology explaining how risks are calculated, monitored, reported, and updated.
  4. Over-relying on outdated assessment models that incorrectly assess the inherent and residual risks.
  5. Incomplete or poor-quality data required to validate and quantify the level of exposure.
  6. Underestimating the sophistication of financial criminals.
  7. Failing to account for emerging risks such as those associated with new technologies, products, and market developments.
  8. Neglecting the importance of continuous monitoring.

Transitioning to Dynamic, Data-Driven Assessments

Recognising the limitations of traditional annual risk assessments, organisations are now moving towards more dynamic, data-driven approaches. This shift is facilitated by advancements in technology, including artificial intelligence (AI) and machine learning (ML), which enable real-time analysis of transactions and behaviors to identify potential risks as they emerge. By leveraging big data analytics, organizations can continuously monitor risk indicators, adapt to new threats more swiftly, and make informed decisions about where to focus their compliance efforts.

This transition not only enhances the effectiveness of financial crime risk management strategies but also allows organisations to be more agile and responsive in an increasingly complex and fast-paced financial environment.


Financial crime risk assessments are an essential component of modern financial crime prevention strategies. By understanding the importance of these assessments, adopting a systematic approach to conducting them, meeting regulatory expectations, and embracing the potential of data-driven technologies, organisations can strengthen their defences against financial crime, protect their assets, and contribute to the integrity and security of the global financial system.

About Us

We have significant industry expertise in combatting financial crime within global banks and fintechs. Our services extend to obliged entities including insurance, gambling, real estate, and football clubs.

Our expertise is a result of significant time spent within the industry and in senior roles across all three lines of defence coupled with consultancy advisory services provided to our international clients. Our expertise across all aspects of financial crime risk and controls makes us an ideal partner.

We can support you at every stage in the development, implementation, and execution of your risk assessment including recommendations on mitigating controls. We can help you transition from complex traditional assessments to a data-driven, dynamic approach that will facilitate real-time prioritisation of resources and mitigation of risks.

© Copyright 2024. The views expressed herein are those of the author(s) and not necessarily the views of Ankura Consulting Group, LLC., its management, its subsidiaries, its affiliates, or its other professionals. Ankura is not a law firm and cannot provide legal advice.


emea, uk, afc, compliance, risk management, article, f-risk, risk & compliance, anti-corruption, anti-money laundering

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