Campion Willcocks was asked to work with a multi-jurisdictional bank to re-design their financial crime target operating model, including providing a suite of new standards and procedures, and then to assist in the implementation.


Campion Willcocks worked with senior stakeholders to build a new three lines of defence model, based on industry best practice, and undertook a wide consultation process across the business to ensure buy-in. Once the model was approved, Campion Willcocks then created the standards and procedures to sit within the framework, ensuring for the first time that the bank had a consistent approach to financial crime across their jurisdictions.


The client’s Board approved all the proposed target operating model, standards and procedures, and a 12-month programme to implement the new framework was successfully executed. The client now has a framework, which meets their regulators expectations.


We have deep experience in advising clients on their financial crime target operating models and drafting simple and easy to use policies and procedures.