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Best behaviour: A fresh look at financial crime

Best behaviour: A fresh look at financial crime

How can businesses tackle financial crime? The answer doesn’t lie in quick fixes or ‘one-size-fits-all’ solutions.


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As criminal activity grows bigger and bolder, everyone in the business needs to own the solution, says Savvas Koufou.

Costly, complex and increasingly brazen, financial crime is a huge headache for the banking sector. Banks must stay one step ahead of a constantly evolving legislative, regulatory, political landscape. Whether it’s identity theft, credit card fraud, money laundering or another systemic illegal activity, financial services firms are now suffering significant commercial losses – with digital technology simply fuelling the ingenuity of the crimes. There is also societal and government pressure on banks to tackle financial crime in order to protect our communities and national security. 

How can businesses tackle this constantly-evolving industry challenge? The answer doesn’t lie in quick fixes or ‘one-size-fits-all’ solutions. It is not about placing responsibility solely at the doors of the compliance function and risk management teams. Nor is it about relying entirely on tighter controls and monitoring. 

What it is needed is far more radical: a holistic response to risk embedded in the people across your entire organisation. In other words, everyone from the front line onwards feeling motivated, skilled – and confident – enough to play a key practical role in stamping out financial crime.

Creating a can-do culture

For many businesses, that adds up to a major shift in corporate mind-set. That’s why, drawing on our extensive experience of supporting clients across the sector, KPMG has developed an innovative portfolio of learning programmes to achieve precisely that community-based transformation. 

We realised that in order to achieve the right confidence, skill, and motivation in people to help bring about that shift in mind-set we needed to bring together everything we know about learning and about risk. These new programmes combine insights from not only KPMG’s in-house financial crime experts, external risk firms, but also our deep learning and behavioural science subject matter experts. 

The result? Highly tailored learning programmes, delivered using immersion techniques designed to get real results in terms of immediate and long-lasting behaviours. Not just for the top table, but primed to reach every single corner of the organisation and create a comprehensive and lasting capability framework.

Making the difference, fast

With the backdrop of increasing regulation, complexity and new ways of doing business, we are working with firms to lead the way in creating and embedding financial crime learning throughout the ranks with agile, interactive and micro learning, accessed on the go, 24 7 says Karen Briggs.

What sets this approach apart? It’s an interactive learning solution within financial services, highly practical, immediate and anchored in real-life scenarios: as far away from a traditional dusty classroom set-up as it’s possible to be.


Micro learning – bite size elements, compressed into 10 to 12 minutes, using game mechanics and techniques to drive engagement such as scoring, and highly graphical interfaces. This gives the experience of an interactive movie or mobile game.

Each individual employee is directly in charge of their own experience, they make decisions and choose their own path, learning from the consequences of their decisions. Our research tells us that encouraging learners to make those decisions for themselves stimulates higher cognitive load in the brain, providing a far higher rate of information retention, compared to a retention rate of as low as 10% from more standard learning techniques.*

Real-life risk

We take the same approach to classroom content. Using fully immersive scenarios created to be as closely as possible related to the individual’s day to day role within the organisation. By providing an experience instead of passive, lecture-style learning, we see increases in confidence and a willingness to engage.

The training modules can be adapted from frontline staff all the way up to leadership and senior management, to ensure that the cultural change genuinely embraces the entire business from one end to the other. 

Happy clients, tried-and-tested result

Just how well this approach works in practice was illustrated recently by the positive response we received from one of our major banking clients, after we created and implemented a large-scale customised financial crime transformation programme within the business.

The project involved a total of 18 different training modules across 20,000 staff across the UK, with six modules prioritised to focus on specific areas within the organisation. The design of the training products took just six weeks from conception to deliver and we used agile storyboarding techniques to develop the training and test it in real time, to ensure it achieved its objectives.

Employees within the bank gave the training process a score of nine out of ten after they had participated, reporting that they felt far more comfortable asking questions than within a classroom set-up – and gained a much better understanding of how to deal with the issues they faced. 

*The Forgetting Curve

© 2020 KPMG LLP, a UK limited liability partnership, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved.

KPMG International Cooperative (“KPMG International”) is a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

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