It is a cycle that many companies find themselves in. Half way through (if you are lucky) a KYC/CDD remediation programme, the goal posts are moved and files that were previously deemed complete, have to be “Re-remediated” – or re-adjusted – to the new standards.

So, how can an organisation get off this hamster wheel of never ending updates and into a business as usual (BAU) state?

The only way to escape this interminable state is to get stakeholders to agree to a line in the sand, which – to ensure best practice – has a number of key stages:

1. Periodic updates not ad hoc: firstly, the team has to work closely with Compliance to agree that changes to policy will be released periodically (so teams know when to expect updates) vs adhoc
2. Regular reviews: it is important to seek agreement that regular reviews can be the vehicle to bring Low risk files up to evolving standards
3. Version control: version control of standards is vital so that each file can be mapped back to a specific policy version when it is being checked by internal and external associates
4. Fast track high risk files: setting up a fast track re remediation / review process for high risk files where a regulatory change demands an immediate
5. Timeframes: it is important to agree a sensible timeframe to remediate the existing population of documents and prioritise the order of the remediation using a risk based approach
6. Find a balance: split the team between the remediation work stack and the BAU regular reviews to ensure both populations are being managed
7. Keep finger on pulse: keep track to ensure that the remediation workload is coming down and new BAU reviews are being closed to plan and incentivise team members where necessary
8. Quality and Quality: ensure that in the rush to get files completed that quality is not sacrificed as this will come back to bite you later on.

P2 FinCrime has helped clients to regain control and exit remediation through a well governed, documented and syndicated process. This ensures that all internal and external stakeholders understand the decisions that are made and that clear documentation of the decisions and analytics exists for future reference.

P2 FinCrime runs training academies for KYC analysts, reviewers and Quality Assurance specialists to ensure all are operating to a consistent standard, using the same terminology, reference points and marking standards to ensure a consistent approach to production, checking and approval.

P2 FinCrime is happy to provide support to the set up of a remediation capability or assess in-flight activity with benchmarking, to ensure a programme is on the right track. We do this in addition to an ‘analyst training needs assessment’ and the adaptation of training materials to fill any gaps in knowledge that might be specific to your organisation.

If you would like to learn more or to discuss any of the above please contact me on:

Phil Rolfe, CEO of P2 FinCrime
phil@p2consulting.com
+44 (0) 7798 666454