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To ensure that we align our work in fighting financial crime with industry best practice and the changing expectations of our regulators, we have a clearly defined governance structure. Its focal point is our Group Financial Crime Risk Committee, which meets six times a year and is chaired by the Director, Property, Research and Assurance.

The Committee sets our overall strategy for combating financial crime. This is informed by the Group’s assessment of emerging risks and changing regulatory requirements, comparing them against current systems and controls. Progress against the strategy is measured across businesses, functions and individual territories.

Figure 1: Our financial crime governance structure

Annual Report and Accounts 2010