Financial Crime & Compliance | Setup of a new organization related to international sanctions alerts filtering

Client Needs & Objectives

Following a major sanction and a subsequent remediation plan committed to the US regulator, our client needed to build a new organization regarding International sanctions management framework, for all APAC entities:

  • Replace the current 4 level organization by a more robust 3 level escalation framework, and centralize, when possible, the Alert Management functions to avoid treatment heterogeneity with APAC
  • Create a specific first level team in APAC to cover Global scope
  • Review all processes related to the investigation of alerts generated for APAC entities based on Group guidelines

Our Approach

1. As-is mapping of current alerts management framework

  • Identification of current organization and processes for 13 sites and multiple business lines across APAC (40+ teams)

2. Design of a Target Operating Model

  • Assessment of target scenarios (centralized / decentralized)
  • Regulatory filing (process outsourcing) when needed
  • Design of target workflow, processes and tools

3. HR initiation (transfers/recruitment), onboarding and trainings

4. Deployment of the new organization

  • Core package deployment and Go Live
  • Stabilization and monitoring of the production (post-Go Live)

Main Deliverables

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Client Benefits & Main Results

Beyond the Compliance with new Group policies, this new setup brings several improvements in the management of alerts related to international sanctions:

- Tighter controls over transactions

- Homogeneous handling of alerts by Operations & Compliance teams across the region thanks to centralization of processes in regional hubs with 40+ dedicated HC

- 60% decrease of the number of alerts escalated by the 1st level

- Scalability of the setup, allowing to absorb workload peaks

The project has been successfully delivered according to the ambitious initial planning