crime teams are under pressure to prove that policies work in day-to-day operations. A credible control framework connects customer risk assessment, transaction monitoring, investigations and management information.

The practical test is traceability. Firms should be able to explain why a customer received a particular risk rating, how alerts were prioritised, what decisions were made and how issues were escalated. That evidence should be consistent across first and second line teams.

A focused review can map the framework, sample the hand-offs between teams and identify remediation that is proportionate to the risk. It can also help an MLRO or compliance leader prepare for supervisory questions without relying on unsupported claims or headline metrics.

GRT supports financial crime remediation, framework audits, investigations and MLRO cover as part of the client team.