One of the world’s leading providers of payments infrastructure and messaging, launched a KYC Utility – the KYC Registry – initially for Correspondent Banks in 2015. Beyond were asked to conduct a review of the existing policy (“the baseline”) against regulatory requirements and support a number of critical initiatives in enhancing the baseline.
alignment for KYC Registry
- KYC / AML Policy refresh
- Regulatory mapping (EU / US)
- Effective working groups established across 18 Global Banks, Wolfsberg Group, ICC
global banks engaged with to develop industry standard questionnaire
months to deliver major new policy enhancements
changes implemented to the baseline
"baseline" in line with
The “baseline” for the KYC Registry had evolved over the four years since launch, and it now contained over 600 questions. Our client wanted to streamline the questionnaire but was not clear on how the questions aligned to regulatory requirements and whether they were required or could potentially be removed.
Equally, the KYC Registry was being expanded to Corporates and Non-Banking Financial Institutions and they wanted to ensure that these new policies were aligned to regulation and the existing Correspondent Banking “baseline”.
Furthermore, there was a desire to expand the “baseline” question set beyond KYC to include Sanctions and Sustainability questionnaires.
I am super happy with the work that the Beyond team are doing – I couldn’t have expected any more. The dedication to the project and achieving the right outcome has been particularly impressive. The team are proactive, clear, articulate, understand the subject and communicate really well with my team and the User Group, with whom they’ve established full credibility. Great, great job.
Registry User Group to refine
and evolve requirements
Firstly, our team established a clear view on the baseline questions and consolidated all requests for changes. This baseline was then reviewed and mapped against regulatory requirements, including key implementation guidance documents, and any gaps were highlighted.
The Beyond team engaged the KYC Registry User Group – a group of compliance and operations representatives from over 18 global banks – to refine the baseline and implement changes. This included re-designing the User Group governance process for managing changes to the baseline.
As part of this work, we also worked closely with the Wolfsberg Group, making recommendations for changes to the Correspondent Banking Due Diligence Questionnaire (CBDDQ), an industry standard template.
Our team then collaborated with the internal KYC Registry teams – including operations and technology – to implement these changes to the policy, procedures and ultimately the core technology platform.
We also supported the expansion of the baseline for the Sustainability questionnaire by working closely with the International Chamber of Commerce (ICC), helping to develop an industry standard questionnaire that would help financial services enhance their sustainability approaches.
requirements, with buy
in from global banks
Beyond played a critical role within this project, not only ensuring that the existing policy aligned with regulatory requirements but also helping further evolve the baseline to support critical initiatives. This included a regulatory mapping exercise, the development of a new Sustainability questionnaire, and a number of improvements to the baseline to improve usability, structure and usefulness.
We were very quick to build strong engagement with 18 User Group banks through our regular group and 1:1 meetings, which provided a forum to propose, discuss and agree policy updates. These relationships – plus those in the internal technology, operations and policy teams – helped secure the buy-in needed to make the changes required to the baseline.