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Financial Crime Compliance inherent risk assessment methodology and tool for a Canadian National Credit Union

Client Situation:

  • A small provincial credit union was applying for a federal banking license in order to expand nationally as part of its strategic plan. As a result, they were building compliance and regulatory capabilities to meet federal standards and requirements.

  • As part of the application review, the credit union was required by OSFI to enhance a number of compliance program elements, including the enterprise FCC/ATF Inherent Risk Assessment methodology, in order to obtain the national license.

  • ComplyGenics was engaged to enhance their existing FCC/ATF Risk Assessment methodology as well as to build an assessment tool in order to meet the heightened OSFI requirement.


Our Approach:

ComplyGenics designed and delivered an industry-standard methodology and tool based upon:

  • Leading industry examples of FCC/ATF Risk Assessment methodologies and tools;

  • Discussions with the credit union FCC/ATF Director and staff in terms of specific needs unique to the credit union;

  • Alignment to the credit union’s broader operational risk framework which had also been recently updated; and

  • Other relevant regulatory trends in Canada and the US.


The methodology and tool were reviewed with the client's FCC/ATF Director and team and delivered in the draft as a baseline for further revision by the client. Execution of the initial risk assessment process and related calibration of the methodology and tool was not in scope for the engagement.


The client gained an industry sound example of an enterprise FCC/ATF risk assessment methodology and tool. The deliverables brought together a number of perspectives from industry comparable organizations and served as a sound starting point for the execution and calibration of the credit union’s annual risk assessment.

FCC Risk Assessment Methodology Tool

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