Define the Goal

It can be helpful to set out with some basic goals. Are you trying to reduce inefficiencies or clarify accountability? Or is the goal about accelerating decision-making in escalations, investigations and controls to cut bottlenecks and doom loops?

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Quick Win: Prove the Concept

To prove that change can have tangible impacts, the firm should identify quick, visible changes, conduct analysis and operate a ‘test and learn’ approach to several problems at once. Short term results will demonstrate value and offer opportunities for further improvement.

• Map all major journeys and escalation paths
• Audit missed deadlines or poor outcomes over the past 6 months and categorise the root cause (Too many cases? Wrong SLA? Too many teams involved?)
• Identify the top three ‘doom loops’
• Triage to determine what actions could apply to each. Should SLAs change? Does the process have too many steps? Is training needed?
• Determine which metrics should be used to demonstrate value
• Execute actions in each of the top three and track outcomes in a dedicated dashboard, then show off the wins.

Long Term Planning

With the concept proved, firms can make a long-term plan.

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Mobilisation & Planning

• Develop detailed work plans

• Gather documents and data

• Stakeholder meetings

• Set up project governance

• Kick off sessions

• Decide which controls are in scope

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Controls Review

• Map onboarding and FinCrime processes (1LoD & 2LoD)

• Prepare Controls Inventory

• Review KPIs, KRIs, documentation, audits

• Conduct walkthroughs and effectiveness testing

• Stakeholder interviews to assess control perceptions

• Define RACI (Responsible, Accountable, Consulted, Informed)

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Define Changes to Improve Operational Efficiencies

• Identify inefficient/ missing/ inconsistent controls

• Assess governance, KPIs, escalation processes

• Benchmark against best practice and regulations

• Identify in-house tech/tool gaps

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Remediation Plan

• Categorise issues based on impact

• Conduct capability assessment

• Make a timeline with clear milestones

• Include some buffer time!

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Implementation

• Establish steering committee and finalise RACI

• Develop workstreams and outline dependencies

• Outline communication plans

• Deliver training

• Deliver training

• Deploy tool updates

• Go Live!

• Post Live Monitoring and adjust where needed

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Governance & Oversight

Targeted end to end improvements generate some risks, but these can be mitigated with robust monitoring and oversight. Governance should be the central habit of a change programme, and will set the organisation up for long term success for every other change.

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• A Steering Committee can provide strategic direction, can resolve escalated issues and ensures executive sponsorship and alignment

• A Programme Management function can manage day-to-day deliveries, track milestones and coordinate stakeholders to keep the plan on schedule and to scope

• Working Groups can drive the design and implementation of process change by focusing on specific journeys (e.g. Onboarding, Payments Screening, 2LoD escalation)

• Risk & Controls Oversight ensures changes are compliant and defensible to regulators. 2LoD can offer useful and rigorous challenge

• Metrics, Monitoring and Reporting are needed to track KPIs and progress through regular reporting, dashboards and stakeholder updates.

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Conclusion

DCM has extensive experience designing, planning and executing operational change programmes. This doesn’t always mean buying new systems, and often significant change can be made with close scrutiny of already-existing processes. The DCM team brings deep, hands-on experience from across the financial services spectrum — from global banks to fintechs, with a former approved FCA Skilled Person leading our taskforce of specialists, which gives us a 360-degree perspective that turns theory into action.