When your compliance controls look fine on paper but fail in practice
Most firms only realise their controls don’t work when something triggers scrutiny, an audit finding, a backlog, regulator questions.
Policies exist, training exists but operations don’t line up with risk.
Clear workflows, defined escalation, behavioural thresholds, MI that shows control.
Below is an anonymised, illustrative framework showing how I’ve approached this in practice.
Compliance Operations Framework | CDD, KYC & Risk Controls — BSAH
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