We take a look at how Delta Capita partnered with a multi-national financial services provider to support them with capacity and skills to run a KYC related remediation programme of work supporting them to address a regulatory deadline and comply with their AML obligations.
Background
Our client, the UK arm of a multi-national financial services provider, had carried out a comprehensive review of their KYC/AML framework and as part of the programme of remedial work identified, it required its portfolio of ~3000 UK clients to be repapered and uplifted to new standards. The client decided to partner with a Service Provider, specialising in providing KYC related services, to rapidly deploy an experienced team of KYC resources for an 18-month period to perform this time critical and operationally complex remediation exercise.
Integrating with our client’s own CLM Operations and AML functions, our blended team of 20 skilled and accredited resources, including a senior project manager, team lead, quality control SMEs, and KYC analysts, were deployed to manage this ring-fenced remediation programme of work.
Resources were selected from our pool of talent in our London and New York hubs, so that the team could attend our client offices as required, as well as provide extended time-zone coverage and foreign language capabilities to support screening, client outreach and query resolution for our client’s European, North and South American client base.
When initially deployed, the team went through an intensive 3-week training programme (supported by our client and our own SMEs), as well as an 8-week productivity and quality ramp up period.
Once in steady state, and executing across all components of the KYC process, our team capably led the remediation effort through initial gap analysis; public due diligence; client outreach and follow-up; ultimate beneficial owner determinations; screening; AML escalation; final risk assessment; account suspension; and offboarding.
The DC team implemented a robust governance model with the client stakeholders, including weekly and monthly reporting and regular Governance and Service level meetings to ensure clear and transparent communication, tracking of progress to project milestones, identification and resolution of risks and issues, and to discuss process refinements and improvement opportunities.
Challenges and Solutions
Tracking tool and MI capability: In establishing targets and KPIs with the client during an initial discovery phase, we learned that they had insufficient workflow and tracking tools available to effectively manage the programme of work. To overcome this, we were able to leverage Delta Capita’s data and technology capability to quickly develop a tracking tool and automated management information dashboard (using SharePoint and Power BI) to track the progress of each KYC file, report in granular detail various metrics including daily output of the team members and movement of files through every stage of the process, whilst providing high level weekly and monthly MI and status updates.
Unresponsive clients and procedural enhancements: Unresponsive clients can hinder progress on a remediation of this nature, draining resource and time for little gain. Despite an agreed schedule of frequent chasing and escalation to relationship managers, 3 months into the programme, we had a growing number of files failing to progress as a result of unresponsive clients. Leveraging best practice from a previous complex remediation, we worked persistently with our client stakeholder over several months to gain buy in from their Business, to implement a stringent offboarding process, moving unresponsive clients to a status of suspension and later offboarding after 90 days.
Additionally, our team recommended several other procedural enhancements and simplifications. Notably, advising on the use of an external data provider solution, after authoritative sources had been exhausted, to significantly improve identification and plausibility on key data points to reduce the number of files requiring client outreach. Furthermore, our recommendation to reduce the screening look-back policy from 10 years to 5 years yielded tangible touch time reductions in processing of files.
Key Operating Manual content streamlining: Our client’s KYC key operating manual, like many firms’, was held in a large cumbersome pdf document in an unstructured format which proved problematic to reference easily on a day-to-day basis. For the purposes of the project, leveraging one of our data SMEs, Delta Capita transferred the manual’s content over to a tactical content management system, using OneNote, centralising the content into a single digital platform, with 5 layers of taxonomy to enable structuring of data into related sections, enhancing search capabilities, making it easier and more efficient for analysts to quickly find specific documents, and reference guidelines at the click of a button.
Summary
Deploying a combination of a skilled and experienced KYC team with appropriate span of control, strong governance, transparent and regular communication, and leveraging previous lessons learned and best practice from other similar projects, to supplement the remediation with incremental process improvements, resulted in the project successfully concluding on time and to quality targets with just 7% of unresponsive clients recommended for account suspension and offboarding, as well as bringing tangible benefits that the client could take forwards into their BAU processes.
How Delta Capita Can Help You
Delta Capita has a successful track record in scaling AML/KYC operations rapidly to deliver projects of the highest quality, in line with client policies and timeframes. Our trained experts cover all aspects of the client due diligence review and can be deployed on-site or at one of our managed service centres – either using Delta Capita’s proprietary technology accelerators or, if preferred, the client’s own technology and platform tools.
To find out more and speak to one of our experts, contact us today.
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