Our client, a leading UK bank, had received an unfavourable external review of its Anti-Money Laundering (AML) framework which resulted in a section 166 in the UK. Due to a number of factors the initial response to the review had not landed well leading to:

• Limited visibility of the issues at senior levels;
• Lack of understanding at the top table of the potential impact of the issues;
• Challenges in getting investment in the right areas due to poor coordination;
• Low regulator confidence in the bank’s ability to resolve issues due to a lack of historic delivery;
• Inconsistent reporting to internal and external stakeholders; and
• No macro plan which could be used by executives to track and drive progress.

P2 Consulting joined the EMEA leadership team and completed the following activities:

• Reviewed the regulatory findings and re-prioritised the action plans;
• Built a forward-looking plan with key milestones to enable tracking of change;
• Helped the bank to establish a common AML language that was adopted from top down to enable clearer messaging;
• Helped the Anti-Money Laundering Operating Committee improve visibility of changes and prioritise projects; and
• Supported executives in driving changes across all lines of business to ensure consistent adoption.

Our client bank now has:

• Very clear prioritisation of AML change from the top of the house down;
• Improved tracking of change by senior governance bodies;
• Clear improvement that can be demonstrated to stakeholders;
• Consistent internal and external reporting led to improved confidence in the client’s ability to drive change;
• Improved awareness of the criticality of AML issues across the bank;
• Consistent AML language adopted and used in day-to-day activity; and
• Clear investment linked to issue closure and programme delivery.