With an increasingly globalised banking landscape and vast networks of branches across multiple locations, many banks have faced problems with financial crime and money laundering, and have been hit with substantial fines from regulators.

Our client had been censured by the banking regulators for failing to have sufficient controls in place to assess from where money flows were coming. As a result, the bank was under the strict surveillance of regulatory authorities. Our client needed to evaluate operational risk and manage exposure to risk in relation to Anti Money Laundering (AML) and sanctions while demonstrating that the appropriate checks and controls were in place.

As the programme required a global AML initiative across all business units, P2 Consulting mobilised a team of analysts trained in core banking AML and sanctions regulatory processes. An innovative and agile approach was taken to organise the team structures, with teams representing different geographical regions. All business units were assessed to ensure they had the right systems, policies, procedures and processes in place and were able to run periodic reviews and audits to ensure compliance with AML and sanctions legislation. This discovery and identification work needed to be completed within a very tight deadline to provide timely reports for banking regulators.

Flexibility was key, as the responses from the different business units were not submitted in a uniform way and resources needed to be moved between the different teams in order to cope with the fluctuating workload and meet specific priorities at specific times. We also provided a PMO service to manage the workflow and adopted a Kanban approach in order to track each individual business unit through potentially multiple iterations of review and response.

As the evidence provided by the business units varied in format and content, P2 Consulting needed to develop an assessment process that used both automated and manual checks to process the large volume of data.

We were able to highlight areas of inconsistency between responses and evidence, including areas where year on year variation were unacceptable. These findings were then presented back to the individual business units. The responses back from the business units then had to be carefully analysed to ensure each query could be closed.

We ensured the bank could demonstrate transparent and thorough AML procedures across global business units and avoid further censure from regulatory authorities. This resulted in minimised risk exposure for our client. Additionally, we had a tight time frame (eight weeks) to review all responses from all of the banks business units which would then enable the bank to meet its target of reporting its risk ratings back to the banking regulators.  Our work ensured the bank could highlight any areas of particular risk and then put in place remedial activity in order to demonstrate to the regulator that the bank was in control of its risks.