Three Lines of Defense: Case Study
A Case Study on Client Due Diligence
📅 July 18, 2024
📅 July 18, 2024
When establishing an organizational model to effectively manage financial crime risk and regulatory compliance, we need to enable cohesive action towards enterprise objectives while also providing segregation of responsibilities and avoiding conflicts of interest. The “three lines of defense” is one well-established model to achieve these goals.
What are the three lines and how do they work together? Let’s take a look at a real-life case study of the three lines of defense.
In our previous article we outlined the three lines model and the responsibilities of each team. To summarize it into a few lines, it can be helpful to consider the second line as defining what needs to be done and the first line as identifying how it should be done. We can illustrate this using an example of controls that may be implemented as part of a client due diligence (CDD) framework. For this example, we’ll start with the second line.
The second line of defense undertakes tasks including:
The second line of defense sets standards for compliance, including:
The first line of defense takes action to implement the requirements set out by the second line.
For the sales team, this might include writing and communicating a sales checklist with questions to help identify if potential client is prohibited. The advantage of doing this early in the process is that resources will not be invested in due diligence for a client that cannot be accepted.
For the Know Your Client (KYC) team, the following are examples of elements that could be included in the process manual written to implement second line requirements:
In our CDD example above, the internal audit function would undertake tasks such as setting out an audit schedule for the sales, KYC, and compliance functions to evaluate the effective application of CDD controls. They would document their findings and ensure any required remediation is completed.
The three lines has been and continues to be an effective risk management model. However, in new and emerging areas like digital assets, in-demand skillsets may be scarce, evolving products and markets require novel and innovative solutions, and there may be a need to adapt quickly to regulatory changes. What adaptations need to be made to the three lines model? View our recorded webinar to find out more.
The digital assets sector presents unique compliance challenges, including a complex and rapidly evolving regulatory landscape, misuse of digital assets in financial crime, and the need to adapt existing risk and compliance frameworks to include digital assets. As this industry continues to grow, with projections indicating substantial market expansion, staying ahead of compliance requirements and future challenges is crucial for financial institutions to safeguard their operations and reputation, while benefiting from the potential of this asset class.
Effective defense strategies are paramount to mitigating these risks and maintaining the highest standards of compliance. Led by industry experts, panelists will assess the integral roles of the first and second lines of defense in maintaining rigorous compliance frameworks and will dive into the future challenges that could redefine regulatory landscapes. Prepare to gain actionable insights and forward-looking strategies to elevate your compliance practices in the fast-evolving world of digital assets.
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