Case study

Re-establishing financial crime risks and controls through a practical RCSA

Co-Founder & PartnerAl Catto

A European bank needed a defensible, structured view of its financial crime risks and control effectiveness as part of its response to the regulator. The workstream had to stand up to scrutiny in terms of evidence, traceability and repeatability.

BeyondFS was engaged for three months to establish a practical Risk and Control Self-Assessment (RCSA), anchored to the work actually being performed across the bank's in-scope financial crime processes.

Industry segment
European Bank
Function
Financial Crime / Risk & Control
Core capabilities
RCSA, Process mapping, Risk and control assessment, Residual risk modelling

Key outcomes delivered

A single, evidence-based view: Risks and controls across 5–6 key financial crime processes, traceable from activity to residual risk.
Regulator-ready artefacts: A master Excel RCSA model and a supporting pack showing process maps and risk and control alignment.
A quantified residual risk profile: Supporting prioritised remediation and clearer senior oversight, with defined triggers where residual risk exceeds tolerance.
Built to be repeated: Two client team members coached to run and maintain the assessment going forward.

Approach

An RCSA anchored to the work actually being done

BeyondFS worked with process owners and subject matter experts to map 5–6 in-scope financial crime processes, including onboarding and wider customer lifecycle activities, down to activity and task level.

For each activity, we captured the role or team accountable, the applications used and where handoffs occurred. We then identified risk statements for each activity, mapped them to the bank's risk taxonomy, documented the mitigating controls in place and assessed their effectiveness, taking account of planned technology changes where relevant.

Key elements of the approach included:

Activity-level process mapping across 5–6 financial crime processes, capturing ownership boundaries, systems and handoffs
Risk statements mapped to the bank's risk taxonomy, with mitigating controls documented and their effectiveness assessed
An Excel-based residual risk model using an illustrative scoring approach based on likelihood or frequency and impact, each on a 1–5 scale, including financial impact banding
Playback sessions with SMEs and owners to validate activities, risks, control mappings and scoring assumptions
Coaching for two client team members on how to run and maintain the assessment, supporting internal self-sufficiency

The work was packaged into two core deliverables: a master Excel RCSA model and a PowerPoint pack visualising process maps and risk and control alignment.

Results

programme

months to a regulator-ready RCSA

scope

financial crime processes mapped to activity and task level

self-sufficiency

client team members coached to run the assessment

Outcome

A single source of truth, with a clear line from activity to residual risk

The bank now has a single source of truth for its mapped processes, risks, controls, ownership, handoffs and system touchpoints. Every risk can be traced from the activity that creates it, through the controls that mitigate it, to the residual risk that remains.

The residual risk profile has enabled more focused remediation planning and clearer senior oversight, with defined triggers where residual risk exceeds tolerance. Control owners are positioned to test controls on a periodic basis, with Risk and Compliance leadership able to assure remediation delivery and maintain check and challenge.

The process maps and RCSA outputs are also suitable for training and practical reinforcement of control expectations within frontline teams, and the bank now has the in-house capability to run the assessment again.