At the point of engagement, the scope of the challenge was not entirely clear, however our team rapidly engaged with the client’s core team to identify the main obstacles to successfully delivering this regulatory population within the required timeframe.

Our assessment indicated that the challenge was considerable: Technology systems were not fit for purpose, processes were not tailored the meet the challenge, the team was not appropriately resourced and 3^rd parties were not engaged.

The challenge was made greater by the fact that the annual target had to be met within 9 months.

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.

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.