““It is clear from the tone of global regulators that maintaining a robust, effective and compliant anti-financial crime programme within regulated institutions is top of the agenda. Over the last two years, we have seen this focus extend from large legacy institutions to innovative financial services firms such as virtual asset providers, EMI’s and payment firms. To demonstrate you are robust, effective and compliant means you need to be able to explain how your AFC programme works. We continue to see time and again that firms build controls in a silo rather than viewing them in the context of their wider framework. It becomes disjointed and gaps and vulnerabilities start to appear, whether that be technical system deficiencies, or people or process shortfalls. Target Operating Model sounds like a grand word, but in simple form, it is about being able to explain how your programme works and why that is relevant to your business.” ”