Bonus Toolkit · The AI Forward Broker
The Broker Financial Crime Evidence Pack
A working document for general insurance brokers. The FCA's multi-firm review told the market what it expects written down. This builds the three artefacts that answer it, in one afternoon, not a six-week scramble.
The Broker Financial Crime Evidence Pack
PDF · 10 pages · 6 working sections · Maps to the FCA multi-firm review on financial crime controls
Free to download. No form, no sign-up. Built for principals, compliance leads, and senior managers at general insurance brokers. Use it alongside your own compliance and legal advisers. Not legal or regulatory advice.
Why this worksheet exists
The FCA published a multi-firm review on financial crime controls across insurance firms. If you run a broker, do not read that as an insurer problem. Read it as an evidence request coming your way. When insurers tighten their own controls, they push the pain downstream through onboarding, bordereaux, TOBA scrutiny, delegated authority checks, and post-bind sampling.
The review flagged three recurring weaknesses: group-level policies that are not specific enough at business-unit level, limited evidence of structured risk-based monitoring, and uneven oversight of third parties. This worksheet builds the three artefacts that answer all three. Being mostly effective is not a defence when you cannot evidence it.
What is inside
Six working sections. Run it with whoever owns compliance and at least one person who does the onboarding and checking day to day. Be specific, name people and name systems, and where you cannot answer, write "unknown". It takes an afternoon.
01
The financial crime control map
A one-page RACI matrix mapping who owns sanctions, fraud, bribery, and due diligence. You cannot test or oversee a control you have not first assigned.
02
The risk-based monitoring log
What you test, how often, and what changed as a result. A test that changes nothing was not a test, it was a tick.
03
The third-party oversight register
Everyone who touches customer data or claims, what you rely on them for, and what you would show an insurer if asked tomorrow.
04
The action log
Every gap, every "unknown", and every "never" from the three sections lands here. This is where the worksheet turns into work.
05
Self-score
Score each pillar out of 10. The first run is usually lower than expected. That is the point.
06
The next 90 days
A working sequence, not a project plan. Build the map, stand up the log, complete the register, then pressure-test the lot.
Want a working session to build these?
I will sit down with you and your team and build the control map, the monitoring log, and the third-party register alongside you, so it is done and evidenced, not on a to-do list. No agenda, no pitch.