2022-05-31-奥纬咨询-Sustainability_Is_A_Moving_Target_10页_325kb

Achieving a Sustainable Anti-Financial Crime Program

The report emphasizes the importance and challenge of maintaining a sustainable anti-financial crime (AFC) program in a rapidly evolving environment. Sustainability is a dynamic concept, requiring continuous adjustments to meet changing regulations, risk landscapes, and business needs.

Key Bottlenecks and Challenges

Many organizations struggle with regulatory pressures to implement sustainable AFC programs, particularly during remediation phases, where static operational models fail to adapt to a dynamic environment. In transformation or optimization stages, organizations must ensure initiatives are modular and flexible to accommodate future enhancements, while avoiding premature cost-cutting measures that could undermine effectiveness.

Five Hallmarks of a Sustainable AFC Program

1. Dynamic Target Operating Model (TOM)
   Institutions must anchor their AFC program to a dynamic TOM, regularly updated to reflect regulatory and threat changes. Scenario analysis should inform adjustments, ensuring the program can pivot quickly to address new risks.

2. Flexible and Modular Design
   The program's building blocks (e.g., KYC, monitoring, alerts) must be adaptable to regulatory changes and shifting objectives. Modular infrastructure allows simpler future upgrades and customization of processes.

3. Risk-Based Approach
   Focus on evolving risks and revise tolerances based on maturity and internal/external factors. Risk assessments should inform all program elements, integrating findings from regulatory reviews, audit metrics, and operational KPIs.

4. Cross-Defense Collaboration
   Effective program management requires front-line ownership, coordinated efforts across lines, and clear TOM documentation to map dependencies. Second-line only programs cannot sustain adaptation without timely adjustments.

5. Customization and Proactive Team
   Programs must align with specific institutional needs (size, technology footprint). Ongoing investment in skilled, proactive teams ensures consistent execution and innovation through lifecycle stages.

Building and Maintaining Sustainability

• Establish a dynamic TOM as the blueprint for strategy and resource allocation.
• Conduct regular reviews triggered by maturity shifts, regulatory updates, business changes, or threat evolutions.
• Prioritize initiatives, leveraging risk-based testing and strong internal controls.
• Foster collaboration, with governance models ensuring sponsor and line-of-defense engagement.

Conclusion: A sustainable AFC program requires continuous effort, executive commitment, adaptability, and robust infrastructure to withstand evolving financial crime threats.