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FCC and sanctions risk assessment and implementation for a large technology company


A fintech company with a regulated payments business sought ComplyGenics’s assistance with conducting and implementing an enterprise-wide FCC and sanctions risk assessment to identify and implement sanctions risk and areas for enhancement within its organization.


Problem Statement:

The client faced FCC and sanctions risk assessment exposure associated with their payment services.  They needed to develop a strong FCC and sanctions program to mitigate the risks.  This meant taking proactive steps to test the effectiveness of its financial crime compliance controls and staff awareness at each branch location and location of its direct sales agents.


Our Approach:

  • Identified areas of the business with elevated risks and/or limited control effectiveness were exposed and documented process and procedure to resolve the gap

  • Implemented technical solutions that were recommended for areas of enhancements, including additional areas for the customer and geographical controls

  • Gap analysis and target operating model for FCC and sanctions program were designed and delivered

  • A prioritized list of implementation recommendations for areas of enhanced was delivered


  • Developed a customized FCC and sanctions risk assessment  methodology to assess customer, product, and geographic risk, the design of planned controls, and the residual risk remaining

  • Documented specific observations and recommendations for the enhancement of the program, including technology

FCC & Sanctions Risk

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