Tier 1 global bank
Policy optimisation:
Creating cost efficiency
via policy refinement

In response to a Deferred Prosecution Agreement (DPA), our client needed to implement a set of standard policies in alignment with global policy standards.

The new policy was overly onerous for funds and out of alignment with market expectations. Rollout of this policy would have caused a spike in the cost of compliance (against a backdrop of cost reduction) and resulted in the loss of customers and revenue.

The client required their funds policy to be reviewed and simplified to ensure that they were in line with the market, and that the policy could be adopted in all 56 regions.

The policies for funds required a rapid and extensive redesign to prevent the loss of customers, and the requirement for considerable additional FTE overhead to apply the proposed standard.

Industry Segment
Investment Banking
Function
Client Onboarding
CORe CAPABILITIES
Concise Policy, Reliable change capability, Effective controls
Key outcomes delivered
  • Co-design of policy with client and creation of a simplified desk manual to increase accuracy and effectiveness of policy application
  • Design and implementation of all technology requirements
  • Policy training delivered to global KYC team – c.2000 employees in 3 weeks across 56 regions
  • Global roll-out of the policy to all 56 regions

Results

Cost avoidance
£ 5 - 10 m

of estimated cost avoided by preventing increased compliance costs (based on a requirement of 180 FTE) over the next 12 months

Efficiency
1300

minutes saved per profile, reducing touch time from 22 hours to 15 mins

Training
2000

employees trained in 3 weeks

Stakeholder management
200 +

engaged with the new approach

Challenge
Introduce a new policy
without a spike in
compliance costs

The potential impact of introducing the new funds policy had not been quantified and was believed to be procedurally unworkable by the operations team as it was considerably off-market.

The client was extremely concerned that the introduction of this policy would drive a spike in cost of compliance (within an environment of strict cost reduction) and result in a loss of customers and revenue.

The engagement was highly complex as the approach would need to be adopted in 56 regions across a matrixed organisation within a very compressed timeframe.

Our organisation was progressing with a multi-faceted programme over a number of years with the intention of improving risk and cost controls. We engaged Beyond as they had direct experience of Financial Crime Risk programs within the investment banking sector and were able to apply that experience to our specific requirements and timelines. Their forensic approach and operational rigour enabled the successful implementation of a complex FCR policy change, which delivered material cost savings to the organisation.

Head of CDD
Tier 1 Global Bank
Approach
A measured approach
to stakeholder buy-in

We delivered a small team to work on the client’s challenge.

Our team quickly quantified the time impact of the policy change, developing a business case to support policy simplification and engage senior management to generate the required degree of sponsorship.

We then presented possible options for policy refinement and actively facilitated the discussion between Compliance and Operations to agree the new approach, draft the policy, and confirm the roll out schedule.

Outcome
New policy launched
and embedded within
3 weeks

Once drafted our team conducted a detailed stakeholder exercise to educate the KYC and AML community on the changes. This involved engaging over 200 individuals through 87 separate meetings across 56 regions over an intense 3-week timeframe across 56 regions. This was used to embed and launch the policy.

We very quickly enabled the client to prevent a significant increase in costs and demonstrated our pragmatic delivery capability and concern for regulatory compliance. This helped us to generate trust in the department and to rapidly broker a workable solution for all stakeholders.

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