Case study

Policy optimisation: Creating cost efficiency via policy refinement

Lead partnerMatt Beattie

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
Global Investment Bank
Function
Client Onboarding
Core capabilities
Policy Optimisation

Key outcomes delivered

Development of a departmental vision
Creation of a prioritised change portfolio
Implementation of a project initiation process

Results

Efficiency

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

Training

employees trained in 3 weeks

Stakeholder management

0 +

engaged with the new approach

Challenge

Introduce a new policy without a spike incompliance 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.

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.

“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 BeyondFS 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