Financial Crime & Compliance | AML/KYC Policy writing & design of Operational Procedures framework

Client Needs & Objectives

Following a recommendation from the Internal Audit, our client decided to write a new KYC policy, to align with the group, and to address the audit recommendation

The objectives were threefold:

  • Produce a new KYC Framework, aligned with the Group KYC Policy and amend/update the related operational procedures for the KYC teams
  • Define the planning and roadmap for the implementation of new regulatory measures
  • Optimize the structuration of the operational procedures implementing the KYC Policy

Our Approach

  • Update of the CIB KYC policy: gap analysis between CIB and group policies, definition of the policy timetable and structure, definition of KYC-related criteria by types of clients, products or countries and local responsibilities and specificities, implementation of a dedicated Governance, clarification of the roles and duties
  • Procedures writing and update: impact studies on workflows and KYC IT systems, clarification of priorities between CIB instructions and local specificities, update of existing KYC checklist by client types/ products, workshop and writing of operational procedures
  • Target procedures structure: benchmark the different in-house tools according to the key criteria (User-friendliness, Storage capacity etc.), draft of the decision file to select the tool (if any) including budget and planning and of the business requirements

Main Deliverables

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Client Benefits & Main Results

New KYC policy validated across the board

Adapted and comprehensive operational procedures

Clear governance defined in monitoring, maintenance and update of procedures

Updated process for procedures and related IT solution selected and implemented