Unveiling key challenges in financial crime compliance

by Richard Dunlop, manager, fscom
Financial crime

Share this post

Richard Dunlop of fscom summarises the major points of the 2023 Financial Crime Compliance Report and highlights key issues in anti-money laundering strategies that have been identified.

In a world where financial crime is on the rise, staying ahead of the game in anti-money laundering (AML) compliance is paramount for financial services firms. Following on from last year’s report, The Financial Crime Compliance Report 2023, produced by leading governance, risk, and compliance consulting firm fscom, has shed light on the major challenges that financial institutions faced.

This in-depth benchmarking report, compiled and published by manager, Richard Dunlop provides a comprehensive analysis of the AML frameworks of 60 firms that have been identified as needing further review and enhancement.

This report offers invaluable insights into the deficiencies within AML compliance programmes, which are vital for safeguarding against financial crime.

Fincrime Compliance Report 2023

Top five most affected review and testing areas

The Financial Crime Compliance Report 2023 identifies the following five key areas where deficiencies were most commonly found in AML strategies:

  1. Compliance monitoring;
  2. Customer risk assessment;
  3. Transaction monitoring (TM);
  4. Customer due diligence (CDD – file testing); and
  5. Enhanced due diligence (EDD).

Common issues detected

Across these areas, several recurring issues were identified:

  1. Compliance monitoring: Many firms’ compliance monitoring plans are not fit for purpose and in their current states, do not provide the firm with an adequate level of assurance into the effectiveness of their controls.
  2. Customer risk assessment: The country risk assessment within the holistic customer risk assessment fails to adequately consider and risk rate high risk third countries (HR3Cs).
  3. Transaction monitoring: Firms’ TM rulesets are not of sufficient quality and on various occasions, the rulesets implemented by firms were deemed to be insufficient.
  4. Customer due diligence: The firm had not captured key CDD information, this included a variety of key customer information.
  5. Enhanced due diligence: Firms’ country risk assessments, specifically, how deficiencies regarding the rating of HR3Cs had led, or could lead, to EDD measures not being applied as required.

Access the report today

For those interested in a deeper dive into the findings and recommendations of the Financial Crime Compliance Report 2023, a downloadable copy of the report is now available. It offers firms crucial insights into strengthening their AML compliance programmes in an era where financial crime continues to evolve and pose significant threats.

Commenting on the latest report, fscom’s director and head of financial crime, Philip Creed said: “While this report unveils some noteworthy discoveries, these are not isolated concerns. They represent risks that all firms operating in the financial services sector should have on their radar.

“The report serves as a valuable benchmark, offering insights into a company’s compliance performance and provides guidance on areas that warrant re-evaluation and improvement.

“It’s important to acknowledge that each financial institution faces its own distinctive set of hurdles. While the report sheds light on common weaknesses, it also underscores the importance of addressing the specific issues that are unique to each entity.

“As such, our recommendation is to seek advice from a financial crime expert if you believe that your current processes require a more comprehensive examination.”

The guidance from The Financial Crime Compliance Report 2023 will be incredibly valuable for financial institutions looking to strengthen their AML compliance efforts. We encourage you to review the report and if you have any questions, please don’t hesitate to reach out today.

Richard Dunlop is manager at fscom.

Article by fscom

More To Explore


Are you a member of The Payments Association?

Member benefits include free tickets, discounts to more tickets, elevated brand visibility and more. Sign in to book tickets and find out more.


Log in to access complimentary passes or discounts and access exclusive content as part of your membership. An auto-login link will be sent directly to your email.

Having trouble signing?

We use an auto-login link to ensure optimum security for your members hub. Simply enter your professional work e-mail address into the input area and you’ll receive a link to directly access your account.

First things first

Have you set up your Member account yet? If not, click here to do so.

Still not receiving your auto-login link?

Instead of using passwords, we e-mail you a link to log in to the site. This allows us to automatically verify you and apply member benefits based on your e-mail domain name.

Please click the button below which relates to the issue you’re having.

I didn't receive an e-mail

Tip: Check your spam

Sometimes our e-mails end up in spam. Make sure to check your spam folder for e-mails from The Payments Association

Tip: Check “other” tabs

Most modern e-mail clients now separate e-mails into different tabs. For example, Outlook has an “Other” tab, and Gmail has tabs for different types of e-mails, such as promotional.

Tip: Click the link within 60 minutes

For security reasons the link will expire after 60 minutes. Try submitting the login form again and wait a few seconds for the e-mail to arrive.

Tip: Only click once

The link will only work one time – once it’s been clicked, the link won’t log you in again. Instead, you’ll need to go back to the login screen and generate a new link.

Tip: Delete old login e-mails

Make sure you’re clicking the link on the most recent e-mail that’s been sent to you. We recommend deleting the e-mail once you’ve clicked the link.

Tip: Check your security policies

Some security systems will automatically click on links in e-mails to check for phishing, malware, viruses and other malicious threats. If these have been clicked, it won’t work when you try to click on the link.

Need to change your e-mail address?

For security reasons, e-mail address changes can only be complete by your Member Engagement Manager. Please contact the team directly for further help.

Still got a question?