Step 02 / Explore the workbook

See the risks. Understand the controls.

A visual view of what is inside the Consumer credit edition, before you open Excel. Choose a tab to explore the illustrative worked example.

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Consumer credit

Financial crime risk assessment · illustrative example firm: Quillstone Credit Limited

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29
Pre-seeded risk factors: 5
Risk categories: 05
High or very high inherent risks: 01
Categories above appetite

bwra-consumer-credit-worked-example.xlsxIllustrative data

Illustrative control catalogue

Each control is rated for design and operating effectiveness, with the evidence behind the rating. Showing the 7 weakest of 13.

Proliferation financing assessment and controls25%High Weak
Mitigates: Countries or geographic areas, Transactions, Products or services
Design 2 / operating 1
Basic sanctions-based controls; no specific proliferation financing controls.
Enhanced due diligence and PEP handling50%Medium Adequate
Mitigates: Customers, Countries or geographic areas, Transactions
Design 2 / operating 2
EDD is rarely triggered; procedures exist but are lightly tested.
Transaction monitoring and scrutiny50%Medium Adequate
Mitigates: Transactions, Countries or geographic areas, Customers
Design 2 / operating 2
Repayment-pattern rules in place; scope limited to a few typologies.
Independent audit and compliance monitoring50%Medium Adequate
Mitigates: Customers, Countries or geographic areas, Products or services, Transactions, Delivery channels
Design 3 / operating 2
Internal audit covers financial crime biennially.
New product and technology risk assessment50%Medium Adequate
Mitigates: Products or services, Delivery channels
Design 3 / operating 2
New retail verticals pass a financial crime review.
Third-party, agent and outsourcing oversight50%Medium Adequate
Mitigates: Delivery channels, Customers
Design 3 / operating 2
Annual review of brokers and outsourced providers; limited sample testing.
Customer due diligence (identification, verification, purpose)75%Low Strong
Mitigates: Customers, Products or services, Delivery channels
Design 3 / operating 3
Standard identification and affordability checks with documented exceptions.

Controls in the Consumer credit worked example
Control area	Mitigates	Design / operating	Strength	Example evidence
Proliferation financing assessment and controls	Countries or geographic areas, Transactions, Products or services	2 / 1	25%High Weak	Basic sanctions-based controls; no specific proliferation financing controls.
Enhanced due diligence and PEP handling	Customers, Countries or geographic areas, Transactions	2 / 2	50%Medium Adequate	EDD is rarely triggered; procedures exist but are lightly tested.
Transaction monitoring and scrutiny	Transactions, Countries or geographic areas, Customers	2 / 2	50%Medium Adequate	Repayment-pattern rules in place; scope limited to a few typologies.
Independent audit and compliance monitoring	Customers, Countries or geographic areas, Products or services, Transactions, Delivery channels	3 / 2	50%Medium Adequate	Internal audit covers financial crime biennially.
New product and technology risk assessment	Products or services, Delivery channels	3 / 2	50%Medium Adequate	New retail verticals pass a financial crime review.
Third-party, agent and outsourcing oversight	Delivery channels, Customers	3 / 2	50%Medium Adequate	Annual review of brokers and outsourced providers; limited sample testing.
Customer due diligence (identification, verification, purpose)	Customers, Products or services, Delivery channels	3 / 3	75%Low Strong	Standard identification and affordability checks with documented exceptions.

See the actual workbook · real Excel sheets, rendered from the example file

Consumer credit: Inherent risk heatmap with category scores (illustrative example)

Risk heatmap · opens full size

Consumer credit: Residual risk dashboard against risk appetite (illustrative example)

Residual dashboard · opens full size

Consumer credit: Top ten inherent risks with rationale (illustrative example)

Top risks · opens full size

Consumer credit: Controls assessment with design and effectiveness ratings (illustrative example)

Controls summary · opens full size

Built from the same data and formulas as the worked-example workbook, for an invented firm. All figures are illustrative.

About the Consumer credit edition

Consumer credit lenders and finance providers assessing money laundering and fraud exposure. Check first whether your firm is a relevant person. Reg 10(3)(b) takes some creditors with limited activities out of the definition of a financial institution, so confirm your position with your legal adviser or supervisor. If you are in scope, this workbook applies. If you are not, the same method still supports your wider financial crime risk assessment.