Barclays Bank plc

Governance & Reporting

A written, evidence-based picture of where the firm is most exposed to financial crime, kept current, so money and effort go to the riskiest areas first.

Starting threshold:

Refreshed at least annually and on any material change (new product, new market, M&A, regulatory or threat-landscape shift); every residual risk rated above appetite carries a dated remediation action with a named owner.

First-line owner:

Business unit heads (owning their inherent risk inputs and remediation actions)

Governance & Reporting

Regular, honest numbers and trends about financial crime risk put in front of senior leaders, so problems are seen and acted on instead of being buried.

Starting threshold:

A defined financial crime MI pack delivered to the relevant committee at least quarterly and to the board at least twice a year; every red indicator accompanied by cause, owner and dated remediation; no material adverse trend reported without narrative.

First-line owner:

Financial Crime Operations / MI team compiling the pack

Governance & Reporting

A clear split of who owns risk, who oversees it, and who independently checks it, with named senior people accountable, so nothing falls through the gaps.

Starting threshold:

Every in-scope financial crime control mapped to a named first-line owner and a second-line overseer; MLRO and the accountable senior manager formally appointed and board-approved; second and third line independent of the first line they oversee and assure; responsibilities reviewed at least annually and on any reorganisation.

First-line owner:

Business unit and operations heads (own and run the controls)

Governance & Reporting

People independent of the day-to-day teams regularly test whether financial crime controls actually work, so weaknesses are found internally before a regulator finds them.

Starting threshold:

A risk-based assurance plan covering all high-residual-risk controls at least annually (lower-risk controls on a multi-year rotation); sampling sized to a defensible confidence level; every finding rated, owned, dated and re-tested at closure; no high-severity finding closed without independent verification.

First-line owner:

Control owners (remediate findings); first-line QA where it performs in-line checking

Governance & Reporting

Make sure everyone, especially front-line and high-risk roles, knows how to spot financial crime and what to do about it, and prove they have understood it.

Starting threshold:

100% of in-scope staff complete role-appropriate training at induction and at least annually, with a passed assessment (e.g. >= 80% score); new joiners trained before in-scope access; targeted training delivered within an agreed period of a material regulatory change or relevant incident.

First-line owner:

Line managers and HR/Learning (delivery and completion in their teams)