“In some firms, we found serious deficiencies and required substantial changes to be made.

We often found a culture of wanting to do the right thing, but struggling to translate this into effective execution.

Common root causes were;

• weaknesses in governance and
• longstanding, significant under-investment in resourcing and relevant controls.

This often led to;

• an ineffective risk-based approach
• with poor due diligence and monitoring standards,
• particularly in the case of higher risk business.

 (Rob Gruppetta, Head of the Financial Crime Department at the UK FCA, November 2016)

Although I have not always had the luxury of witnessing the following approach as shown in the continuing statement below (subject to Comsure clients !!!),

I would urge those progressive firms to keep up the good work and those behind the REALITY CURVE to get a grip and join in.

Cont. from above;

Many firms now have extensive remedial programmes,

a clearer tone from the top on the importance of managing financial crime risks, and

better understanding at senior management level and

across all three lines of defence on what is needed to achieve the effective outcomes.”

Rob Gruppetta, Head of the Financial Crime Department at the UK FCA, November 2016