Case Study: Know Your Client (KYC)/Client Due Diligence (CDD) Remediation - Inter-dealer Broker
The Client
A premier voice and electronic inter-dealer broker and provider of post trade risk and information services.
The Challenge
Implementation of a remediation programme to enable the Client to meet its regulatory obligations arising from an FSA Section 166 notice.
A portfolio of 5000 clients comprising various client types (including Corporate, Banks, Hedge Funds, Fund Managers etc), located in a wide number of geographies, with a mix of High, Medium and Low risk ratings.
Timeframe of 3 months.
The Solution
Employment of 2 experienced resources for a 3 month period assigned to work with the Client's front office originators, the underlying Clients, Compliance and Operations to re-paper and uplift each client in the portfolio in accordance with the approved AML Governance standard.
Weekly graphical progress reporting to senior management allowed them to ensure deadlines were met.
The Outcome
The remediation project was completed on time and within budget and passed internal audit scrutiny.
The client's existing on-boarding team and Front Office originators were able to focus on revenue generation, relationship management and core business as usual AML (anti-money laundering) activities.
Remediation of the previously un-reviewed Client portfolio to the approved AML Governance standard meant that the Client's regulatory obligations are fully met.
KYC/CDD Remediation - Global Investment Bank
The Client
A major global investment bank.
The Challenge
Completion of a Remediation Programme following a takeover which necessitated application of each Bank's existing AML governance standards as formal approval from various Regulators had not been finalised.
A mixed population of more than 27,000 clients comprising Corporates, Banks, Hedge Funds, Fund Managers, Soverigns etc), located in a wide number of geographies, with a mix of High, Medium and Low ratings.
The Solution
Sophisticated filtering system to categorise clients into appropriate risk categories (High, Medium, Low) and alignment with the Business to close dormant accounts.
Utilisation of offshore resources to obtain all publicly available client information and administer the process.
Non-publicly available information required the involvement of On-boarding teams who supported the Business.
The Outcome
The remediation project was completed on time and within budget and passed internal audit scrutiny.
The client's existing on-boarding team and Front Office originators were able to focus on revenue generation, relationship management and core business as usual AML (anti-money laundering) activities.
Remediation of the previously un-reviewed Client portfolio to the approved AML Governance standard meant that the Client's regulatory obligations are fully met.