Financial Crime
Financial Crime Control Review
Support for firms strengthening the administrative controls around sanctions screening, PEP workflow, adverse-media review, alert handling and escalation routes.
Overview
Financial crime controls depend on consistent workflows, clear control ownership and documented evidence. BlackCores & Partners helps firms map, review and strengthen these processes to create review-ready evidence and board-ready reporting.
What we can review
- Sanctions screening workflow and trigger points
- PEP screening process and approval routes
- Adverse-media review notes and escalation
- Alert handling evidence and resolution records
- Screening frequency and periodic review triggers
- Client and counterparty risk flags
- Control owner mapping and accountability
- Issue and breach logs
- Management reporting packs
- Escalation and approval route documentation
Circumstances that prompt this work
Most engagements begin from one of the following positions rather than from a general review cycle.
- 01Screening produces alerts that nobody is formally clearing or recording.
- 02Sanctions or PEP workflow has changed but the written procedure has not.
- 03Escalation happens informally and leaves no reviewable trail.
- 04The firm has grown into new markets or products without revisiting control design.
- 05Management cannot demonstrate that controls operate, only that they exist.
Deliverables
What you receive
- 01
Workflow mapping
End-to-end screening workflow documentation
- 02
Control gap analysis
Gaps mapped against agreed review criteria, documented procedures and evidence requirements
- 03
Evidence-quality review
Assessment of screening evidence standards
- 04
Escalation route mapping
Clear escalation paths with owners
- 05
Procedure improvement support
Updated procedures and checklists
- 06
Monitoring calendar
Scheduled screening and review triggers
- 07
Remediation tracker
Action tracker with owners and deadlines
How a typical engagement runs
Stages are confirmed in writing before work begins and adjusted to the scope agreed.
- 01
Scope
Control areas, systems in use and reporting expectations agreed in writing.
- 02
Map
Existing controls mapped to the risks they are intended to address.
- 03
Test
Sample testing of screening, escalation and decision records to confirm operation.
- 04
Report
Control findings, design and operating gaps, and prioritised recommendations.
What stays on file afterwards
The point of the engagement is the record it leaves behind, so a later reviewer can follow the same trail.
- Control map linking risks, controls and owners
- Screening and alert-handling test results
- Escalation and decision-record assessment
- Prioritised control improvement schedule
Who it supports
- 01Compliance teams managing screening workflows
- 02MLROs and MLCOs with oversight responsibility
- 03Financial crime operations teams
- 04Risk management teams
Engagement safeguards
BlackCores & Partners supports financial-crime control administration and review. Services do not constitute regulated financial advice, legal advice or a guarantee of screening accuracy where third-party tools are used.
Financial crime control review support does not constitute sanctions legal advice, screening-tool assurance, regulated financial advice or a guarantee that a screening result, alert decision or third-party data source is complete or accurate.
What we do not do
- We do not provide legal advice on sanctions.
- We do not guarantee screening-tool accuracy.
- We do not approve or clear transactions.
- We do not act as a bank, payment institution or insurer.
- We do not provide investment or financial advice.
Frequently asked questions
What is a Financial Crime Control Review?
A Financial Crime Control Review examines the design, ownership, operation and supporting evidence of controls addressing sanctions, PEPs, adverse media, alert handling and escalation. It considers how these controls work in practice and where evidence, ownership or thresholds could be clearer, subject to the scope agreed in writing.
Can the review assess sanctions and PEP screening workflows?
Yes, within scope. The review may consider screening triggers, frequency, evidence, escalation routes and ownership across sanctions, PEP and adverse-media workflows. It does not guarantee the accuracy of any third-party screening tool, which remains the responsibility of the provider and the firm operating it.
Does BlackCores & Partners clear alerts or transactions?
No. The client retains all operational decisions, legal obligations and transaction authority. BlackCores & Partners reviews how alerts and escalations are handled and evidenced; it does not clear alerts, approve transactions or assume the firm’s decision-making responsibilities.
What may a Financial Crime Control Review Report contain?
The report may include the agreed scope, a control map, the evidence reviewed, observations, limitations, prioritised actions and a management summary. Content varies with the mandate and the evidence made available, and the final structure is confirmed in the engagement letter.
Can this work support an MLRO or board review?
It may support oversight and reporting by providing an organised record of control operation, evidence and observations. The MLRO and management retain their statutory and operational responsibilities; the work informs their judgement rather than replacing it.
Confidential scoping
Ready to review financial crime controls?
Contact us to discuss scope, document requirements and deliverables. All engagements are confirmed in writing before work begins.