The Investment Division of this global financial institution was required by regulators to improve the Enhanced Due Diligence (EDD) reviews of high-risk customers and clear the backlog of required assessments triggered by previous changes to their rating approach. The initial remediation efforts led by internal bank employees did not meet regulatory expectations, leading to additional concerns from risk, compliance, and internal audit partners.
The client's need to strengthen EDD protocols and documentation spanned large and complex customer relationships covering multiple individual and commercial accounts. They needed to stand up a team to execute on the backlog of reviews, train and coach team members, execute quality assurance of risk assessments, and make decisions to retain or exit customers. The Investment Division needed to meet regulator expectations by ensuring that all processes were consistent, sustainable, and repeatable while maintaining the ability to conduct them as Business as Usual activities.
Due to our extensive history of successfully partnering with the client on key risk and compliance initiatives, our deep Financial Crimes experience, and our reputation as a successful embedder of sustainable, repeatable controls, Eliassen Group was chosen to deliver on this engagement.
We executed the following steps to achieve our intended result:
- Performed gap analysis identifying impacted populations, requirements to clear backlogs, and concerns raised by risk leadership, Internal Audit, and regulatory examiners.
- Understood expectations of what success would look like and clearly defined how to identify, analyze, and document risk-based decisions to retain or exit customers.
- Drafted, validated, and deployed desktop procedures enabling consistency across reviews.
- Deployed multi-phased production model, enhanced workflows and procedures. Production model aligned resource skill sets to key activities and streamlined operations.
- Completed multiple quarterly Enhanced Due Diligence review cycles.
- Rebuilt relationships and trust with key Risk Management and Internal Audit stakeholders and met critical dates with high quality deliverables.
- Deployed a full-scale team of experts including QA, training, data management, and reporting to enable process stabilization and overall sustainability.
- Developed a roadmap for sustainability that included ongoing communication of priorities, senior leader engagement, reporting and implementation of a continuous improvement approach.
- Enhanced overall program governance including high-risk customer reporting and sustainable resourcing models.
Eliassen Group's efforts enabled the client to successfully meet all regulatory requirements. We also supported the first Internal Audit Rating upgrade of Anti-Money Laundering Function within the Investment Division in six years. We completed this project under budget and our team was repeatedly recognized by Investment Division executives as a leading practice to emulate.