- It is important for firms to consistently review and assess their organisations’ ability and effectiveness to detect potential links to IWT at all levels of the business.
- As with any risk & control framework, it is important to test and measure the effectiveness across different levels of the organisation so that you can continuously adapt and improve your corporate response and culture.
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An enterprise wide monitoring plan is developed and completed using the ‘Three lines of defence model”. Broadly this incorporates:
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1st line of defence: Quality Assurance (QA) – scoring and assessment done on an individual / team basis by each respective team or business QA function;
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2nd line of defence: Compliance monitoring – periodic assessments of your IWT policy and procedures across specific thematics or sections of your organisation;
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3rd line of defence: Audit.
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Any assessment results are incorporated into a firm’s performance management framework and ongoing training needs analysis.
- Senior management should challenge the strength and effectiveness of IWT related controls through a combination of internal and external reviews looking at the company’s adherence to both internal policy and external regulation and best practice.
- We would also encourage firms to complete firm wide corporate culture assessments as an alternative way of assessing and checking the understanding of IWT and the practical application of your specific control framework across the organisation.
- Senior management should be kept up to date of emerging threats, trends, criminal techniques as well as legal and regulatory requirements through detailed and regular horizon scanning reports.
- The business risk assessment is dynamic and regularly updated to incorporate new threats, criminal techniques as well as changes to business strategy.
- Results of regular assessments are used to update the firm’s IWT framework, their performance management process and their training needs analysis.
- A positive culture and tone from the top reinforces the importance of IWT on a continuous and ongoing basis.