September 29, 2021

We like to take a pragmatic and hands-on approach in our work with FIs on the topic of FEC prevention. It’s important to have regulations, policies and control measures in place but we believe it all starts with ‘getting it right the first time’ and making sure that all staff interacting with clients and transactions actually comply with the policies on a day-to-day basis.

Making staff understand the policies and adhering to them is difficult enough when employees are located in the same building. It becomes more complicated if teams work from different office locations across countries and regions and even more difficult when people no longer work under the security and oversight measures that exist in traditional banking offices.

Bank staff have been working outside offices for the longest time of course. People travel, work from coffee shops, hotel rooms, their home and client offices but that used to be the exception to the rule. Since the pandemic started early last year, financial institutions have had to cope with Working From Home (or WFH in short) but the consequences and (dis)advantages are not 100% clear yet.

The Financial Times have published articles with titles like “JP Morgan calls bankers back to the office from July” and “Hybrid working makes it harder to detect fraud, auditors warn”. The Economist has looked into productivity and employee engagement aspects recently (see here and the figure on the left)  and many other magazines and organizations have voiced an opinion on the matter.

At i-KYC we of course cannot oversee all aspects involved in the decision but we can give 5 points to consider from an operational compliance perspective.


  1. Trends and opinions from industry leaders matter but not every organisation is the same. What works in a startup might not work in a traditional bank and what works for a money changer might not work for a digital payment service provider.
  2. Talk to your staff and try to come up with a model that everyone supports; forcing a work schedule on your employees is asking for trouble.
  3. Do a proper risk assessment to ensure you understand when and where WFH is possible.
  4. There is no one size that fits all; tasks and jobs are different, some tasks can be done at home, some cannot.
  5. Lead and manage your people; WFH is different than working in an office and with a blended model more complications are added. That needs to managed, employees need clarity, guidance and direction to stay engaged.

Managing FEC risks starts with a thorough risk assessment. Knowing and understanding the financial crime risks in the company – including the additional risks of WFH – is the starting point for managing and mitigating these risks. Find more on our risk scan here or email us for a free consultation.