Case Study Drop Downs
There was no budget for new software, so we updated the AML/CTF governance and created a KYC onboarding procedure that worked with existing systems. New controls were put in place and revised KYC assessment were implemented, fulfilling the client’s need and including all training and desktop process mapping to complete the governance suite.
Once the project plan was agreed the process would then take them through Option B to permissions being granted, then on to launch. There was an existing CCA function providing local business loans as well as mortgages through the Housing Act provisions for local authorities, and these were to migrate to the bank as and when the mobilisation phase was reached.
Specialist consultants were deployed to create the necessary areas for development of the business plan and co-ordinate the elements into a full application.
Compliance Consultant was asked to perform a gap analysis and project plan creation of a small financial operation including a bank.
The previous incumbent had left an array of notes but the dates and sequence were often missing. Our task was to collate, assess, analyse, apply to latest SMR requirements and identify the documents needed to be reviewed and updated. There were several external stakeholders including two sets of legal firms.
We created a workable and pragmatic action plan and identified the key steps, recording them on a project plan with milestones and phases differentiated for implementation. The project plan was created to include the whole implementation phase until March 2017.
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For ICAP plc (an Inter-Dealer Broker) Compliance Consultant (Formerly CEI Compliance) were tasked with reviewing and defining a new risk framework, loss reporting and streamlined, cohesive linked system to manage their risk exposure.
Here we identified misapplied rules and inaccurate ratings applied to the risk process. We identified time wasting elements and log-jams as well as disconnects and dead ends of the current system.
By re-engineering the process and creating a relevant and pertinent taxonomy, with risk identification along the lines of industry best-practice but specially formulated to identify the uniqueness of the client’s operations, we provided a range of solutions and options to assist in Risk Management and production of their annual ICAAP document, resulting in significant savings to their regulatory capital requirement.
It was soon evident that there was a need for an overall review of each and every sale as there was poor documentation and minimal suitability evidenced in any of the files. In a short time we assembled a group of specialist reviewers and completed the work within 3 weeks.
The final result was a fully compliant suitability appraisal of some very poor files and documented evidence that there was no duty of care demonstrated to even a “Treating Customers Fairly” standard.
The intention was to create as near as possible real time web based depositary from all the entities worldwide to provide the global position of all UK and dual listed securities.
Following on from this work the system was then expanded and we advised the inclusion of all global equities with the application of the data provided to the Research Department in Johannesburg to be able to have up-to-date positions so that they could declare any conflict of interest on any research material, a requirement by multiple jurisdictions around the world.
As part of the brief for the Zurich Banking Group, there was a need for an Operational Risk Framework to be rolled out worldwide. Originating from Switzerland this had been delayed for some time due to staff issues.
The banking group, unlike the global insurer, spanned four jurisdictions and each had separate processes that need to be identified, recorded (with primary and secondary controls identified throughout) and uploaded into the global main risk database in specific formats.
We coached and assisted the various process owners in the recording of the processes and facilitated further course design. Additionally, the reporting tool (SWORD) application needed implementation including training of all staff. Launch was co-ordinated to ensure required collation of all losses, near misses and breaches were fully registered, escalated and approved as appropriate.
These assessments were also checked against contemporary Treating Customers Fairly practice and the standards applied retrospectively, ensuring that the customers had a fair deal and that no one was given a bad customer experience.
And so much more ….