Financial institutions are increasingly looking to build and maintain sustainable Anti-Financial Crime (“AFC”) programs that can adapt to various conditions, as they move through maturity stages, from remediation to transformation to optimization. For many organizations, this objective often comes on the back of regulatory feedback pushing for “sustainable” programs. However, while sustainability is a critical concept, it is also a dynamic rather than a static one, which requires continuous attention and dedication, particularly in the context of an always changing environment: a sustainable AFC program today may become an untenable one tomorrow.
Achieving sustainability in financial crime risk management requires organizations to define a dynamic target operating model, continuously tracking evolving requirements and the changing environment. This target operating model should direct the functioning of each component of the AFC program, inform priorities and ensure coordination across the lines of defense. While there is no single way to achieve dynamic sustainability, we have observed a number of shared features among programs that successfully achieve, secure, and maintain this state. Institutions can achieve dynamic sustainability by minimizing short-term tactical fixes, establishing, and communicating a clear program vision, ruthlessly prioritizing initiatives, actively coordinating across stakeholders, establishing an effective governance framework, and investing in a proactive team.