Case Studies

Bringing financial crime compliance into one governed program

Written by Avocado Marketing | Oct 8, 2026, 4:33:20 AM

How an Australian mutual bank turned more than seven separate reviews and initiatives into one prioritised, auditable program of work in eight weeks.

About our client

Our client is an Australian mutual bank, a member-owned financial institution without the scale or dedicated compliance resourcing of the major banks. As a regulated institution it carries the same obligations as much larger players, including AML/CTF requirements and the incoming Scams Prevention Framework, with a fraction of the headcount.

The challenge

  • Two independent AML/CTF reviews, a Scams Prevention Framework review, a position paper and an existing financial crime roadmap all ran in parallel.
  • The existing roadmap mixed active and paused projects, with no single view of scope or priority.
  • A small team needed a program structure it could sustain on its own, long after the engagement ended.

Our approach

  • Discovery and alignment through sponsor workshops, a stakeholder map and 20 to 25 one-on-one sessions.
  • A single program charter endorsed by the CRO, CTO and Head of Financial Crime.
  • Consolidated scope: all sources into one requirement set, around 80 items reduced to roughly 50.
  • A structure sized for a small team: two workstreams with a combined fortnightly forum.
  • A prioritised, risk-rated roadmap across design, implement and embed phases.
  • Governance and reporting, including a self-updating tracker that flags overdue work.
  • A clean handover with an Executive Committee presentation and documented handover pack.

The outcome

  • In eight weeks, the bank moved from seven-plus disconnected initiatives to one governed program with clear ownership and sequencing.
  • Duplicated scope was cut by around a third.
  • A prioritised, risk-rated roadmap gave a defensible answer to any regulator.
  • A live tracker gave full visibility of progress and resourcing pinch-points.
  • The program was on track for completion ahead of the next independent review.

Related

Juggling multiple reviews with a small team? Talk to us about a Governance Framework Review.