Challenge
A multi-institution review required comparable testing while recognising differences in business model, scale, customer base and inherent ML/TF exposure.
Approach
The programme used a common risk-based framework for governance, customer controls, screening, monitoring and reporting, with institution-specific sampling and calibrated findings.
Outcome
Each institution received an evidence-based view of design and operating effectiveness, while programme leadership gained cross-cutting insight into recurring control themes.
Impact
The experience covered over 30 regulated institutions and is identified as leadership and practitioner experience, not solely as an FCT corporate engagement.