SUMMARY
Since January 2022, Avantage Reply has been supporting an important European universal bank in their implementation of the Anti-Money Laundering (AML) remediation plan imposed by the local supervisory authority.
The team of 15 consultants, ranging from consultant to senior manager, provides an on-going support in the areas of team management, the development/implementation of internal processes, file review, as well as transaction monitoring analysis. They are positioned to work as compliance analysts, dealing with files and bank accounts of the Retail, CIB (Corporates, Institutions) and Wealth Management (European and Non-European private banking, Business Owner and Family Office) customers.
Avantage Reply’s team, continues to provide daily support to the bank following the completion of the project‘s implementation phase. The team assists in the ongoing processing and review of files and contributes to the continuous improvement of internal processes in line with the latest regulatory updates in AML and KYC guidelines.
CUSTOMER GOALS
Following the inspection and the subsequent report from the local supervisor, the client had developed an action plan focused on reviewing the files of customers with the highest AML risk.
At this point in the project, the emphasis has shifted towards improving the quality of the review process for each file by adopting a more qualitative approach. The goal remains to successfully implement the actions and recommendations required by the local authority within the defined timeframe and to ensure a comprehensive review of the bank’s customers in compliance with AML regulations such as:
• To create an acceptance and on-boarding procedure for new customers and assessment of the relationship for existing customers
• To produce an AML risk assessment
• To systematically monitor for atypical transactions and perform adequate vigilance for cross-border transfers
• To perform adequate customer file analysis and customer file review
• To proceed with the blocking of accounts and/or the exit of customers that do not comply with the remediation program and the requirements of the AML regulations
CHALLENGES
At the beginning of the project, Avantage Reply, together with other consultancy firms, was involved in supporting the client. However, since January 2024, Avantage Reply has become the sole consultancy firm assisting the client on this project. Avantage Reply’s consultants deal daily with complex and challenging situations to carry out their work effectively and to meet tight deadlines. In some cases, this complexity arises from internal and organisational processes that are in place, which are often adapted to meet the client's evolving needs.
SOLUTION
Avantage Reply has engaged its experienced consultants in the financial crime and anti-money laundering compliance fields to support the client in performing customer file reviews and transactional monitoring of corporate, private and institutional customers. Leveraging its expertise, the team has successfully maintained the client’s trust, remaining the sole consultancy firm involved in the project.
The majority of consultants are engaged as Compliance Analysts, responsible for the full review of customers, including the application of Know Your Customer (KYC) and Know Your Transaction (KYT) requirements, as mandated by the European and local regulations.
The consultants help the bank manage a significant volume of files that need to be reviewed within the imposed deadlines.
Some Reply consultants are engaged as project managers by the client to manage, monitor, enhance, and optimize the remediation program as well as the internal procedures and policies of the bank. Furthermore, certain Reply consultants are also involved in other teams within the KYC office, such as the Dormant Accounts and Exit team, to support the client in the closure of accounts and exit of customers where the remediation process led to termination of the business relationship or for other regulatory or commercial reasons.
CUSTOMER DESCRIPTION
The client is a universal bank providing services in retail banking, private banking, wealth management, institutional banking and corporate banking.