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Case study

Strengthening a UK Building Society’s FinCrime framework to deliver regulatory confidence​

Josephine Seymour
Lead consultantJosephine Seymour
Lead consultantJosephine Seymour

A newly appointed Head of Financial Crime at a major UK building society inherited a programme with very limited documentation. With potential regulatory scrutiny on the horizon, she needed independent assurance that policies were complete, aligned with UK MLR and JMLSG guidance, and that they were accurately reflected in operational procedures.​​

BeyondFS was engaged to conduct an extensive mapping exercise, linking policy requirements to corresponding procedural documents, processes, management information and controls across anti‑money laundering, sanctions, transaction monitoring and customer due diligence. We were chosen for our deep regulatory expertise and industry knowledge.​​

A key challenge was that much of the team’s knowledge was held informally by experienced staff rather than captured in formal documents, making traceability and assurance difficult.​

  • Industry segment

    Building Society

  • Function

    Regulatory Review

  • Core capabilities

    Strategic Review, Financial Crime Prevention

Key outcomes delivered
  • 35 prioritised findings – including one high‑risk gap flagged early, with clear, actionable recommendations.​
  • 90+ policy statements mapped end‑to‑end – from policy to procedures, MI, and controls, creating full traceability and highlighting consolidation opportunities.​
  • Board‑level confidence restored – client left prepared for regulatory scrutiny with a clear, practical remediation path..​

Results

Recommendations

0

thematic recommendations

Review

0 +

artefacts reviewed

Accelerated process

0

week process

Approach

An accelerated process over 8 weeks

Over eight weeks, we delivered two complementary workstreams:​

  • Regulatory Review – We assessed the full suite of Level‑1 and Level‑2 financial crime documents against UK MLR and JMLSG guidance, partnering with a firm that specialised in the technical aspects of compliance when QA‑ing the outputs. This process confirmed policies were accurate, complete and aligned to industry standards.​

  • Policy‑to‑Operations Alignment – We mapped each policy requirement to its corresponding procedures, MI, and controls, creating a full traceability view. This exercise highlighted where policies weren’t fully embedded in operations, where documentation could be streamlined, and where supporting evidence was needed.​

We worked closely with the client to ensure recommendations were proportionate to their UK‑only, low‑risk business model, positioning the review as collaborative rather than critical to encourage openness and early issue resolution.​

7
Outcome

Regulatory confidence and clear recommendations

We delivered 35 prioritised findings, including one high risk gap in Customer Risk Assessment flagged early to avoid regulatory surprise. Each came with clear, actionable recommendations, from urgent fixes to operational improvements.​

Our report, with an annotated policy suite and a traceability map of 90+ policy statements to procedures, MI, and controls, gave the Head of Financial Crime, MLRO, and Board a clear view of gaps, priorities, and consolidation opportunities – leaving them better prepared for scrutiny and with a clear path to strengthen the FinCrime framework:​

  • Regulatory confidence – proactive gap identification;​
  • Evidence based planning – findings driving a practical remediation plan;​
  • Clarity and traceability – streamlined, aligned documentation.​