FCA ‘POOR PRACTICE’ EXAMPLES | | CLEVER NELLY BENEFITS |
“There is little evidence of senior staff involvement and challenge and practice. A firm concentrates on narrow compliance with minimum regulatory standards and has little engagement with the issues.” | | Continual assessment of financial crime competence demonstrates a clear move away from narrow / tick-box approaches to employee compliance. |
“There is no meaningful record or evidence of senior management considering financial crime risks.” | | Firms receive daily, real-time, objective Management Information showing where competence-related financial crime risks are manifesting within their organisation. |
“A firm has no strategy for self-improvement on financial crime and issues are dealt with on a purely reactive basis.” | | Clever Nelly automatically assesses and repairs individual competence gaps in the flow of work, proactively supporting a strategy of self-improvement. |
“The firm makes no effort to understand or address gaps in its financial crime defences.” | | Clever Nelly provides granular, best-in-class reporting and evidence of staff competence in relation to their financial crime knowledge. |
“MI does not help senior management to understand the financial crime risks in which their firm is exposed.” | | The Management Information provides firms with a forward-facing risk radar, showing where competence / confidence is sub-optimal. |
“The firm fails to check whether policies and procedures are applied consistently and effectively.” | | Continual assessment enables firms to assess and improve employee behaviours associated with adherence to policies and procedures. |
“The firm fails to identify training needs.” | | Clever Nelly continually assesses individual employee training needs, repairing knowledge gaps in the flow of work, whilst highlighting where immediate intervention is required. |
“New staff in customer-facing positions do not receive financial crime training tailored to their role before being able to interact with customers.” | | Clever Nelly typically improves speed-to-competence for new hires by 30% using continual assessment; completely personalising the learning experience for each individual. |