The Financial Crime (FC) Function is a Second line of defence (LOD) function that includes “Risk Stewards” who are independent of the commercial risk-taking activities undertaken by the Group’s businesses (also referred to as “the First LOD” or “FLOD”). The FC Function also operates a set of critical controls on behalf of the FLOD by harnessing intelligence, analytics, technology, detection and investigation. The Risk Stewards are responsible for reviewing and challenging all the activities of the FLOD to ensure that, as “Risk Owners”, the FLOD effectively manages the FC risk inherent in, or arising...