In today's article we outline our high-level strategy for effective team mobilisation within the time critical KYC remediation space.
We zero in on two specific areas:
The critical first four weeks to ensure faultless delivery
Implementing the blueprint for operational excellence.
The First four weeks
o Team mobilisation & operational readiness
o Unity of vision, controls and rigour
o Training and rapid upskilling
o Robust governance structure
o Forecasting and capacity planning
o Team structure & roles and responsibilities
Target Operating Model
o 3 month overview of target state on-going activities
o Embedding the optimal way of working
o Control environment and governance
o MI & Reporting and escalations
High level planning considerations
Pipeline assessment: Establish a pre-allocation process & ensure clear line of sight over case volumes and complexity
KYC processes: Map out end2end processes & agree SLAs. Seek buy-in and unity of vision with key stakeholders
Framework: Design relevant frameworks to operationalise KYC/AML standards
Training: Build a training plan to provide rapid up skill and knowledge transition for existing team & future cohorts
Ramp-up plan: Road map to ensure analysts are fully operational by an agreed juncture
Forecasting and capacity planning: Establish in/out of scope activity. Agree productivity & quality expectations.
Interaction: Define the rhythm of interaction with the delivery team & key stakeholders
Governance: Build a robust governance structure to facilitate rapid decision-making and issue resolution.
Control environment: Establish an effective controls environment to ensure risks and issues are captured and mitigated
MI: Build robust MI to measure & communicate progress. Identify common problem areas that may yield opportunities for continuous improvement
Transparency: Build in practical measures to ensure transparency of operation (plan for regular engagement, pledging mechanism, hot lists, whiteboard sessions).
c.30 person Remediation Team
This structure provides a robust support network and allows for high-level interaction, effective collaboration and knowledge transfer. Delivery teams tend to be more autonomous and self-steering when operating in smaller dynamic groups.
20 x KYC Analysts responsible for file remediation, screening, outreach, public domain searches, file preparation and submission.
5 x QA specialists responsible for performing QA , identifying error themes, providing training and upskilling where necessary.
Cells to be agile and interchangeable to support knowledge transfer if necessary
QA‘s to review files of their individual pod. QA’s to be interchangeable if there is an imbalance of work.
The Engine Room
SNAP SHOT of daily operation
Daily Team meeting [Macro issues, communicating priorities and focussing on outcomes]
Daily Break out pod meeting with team [focused on micro issues & troubleshooting at source, analyst support]
Daily review and scrutiny of throughput & quality. Assessment of risks and issues precluding team from working at optimal levels
Effective pipeline management (prioritising case load / identifying quick-wins/ tackling cases by groups to drive productivity)
Establish a ring-fenced team possessing a more investigative and EDD skill-set to work on High Risk cases to ensure risk exposure is identified early on
QA’s to work closely with team to ensure knowledge transfer and build confidence through early feedback identification and common issues
Daily output posted each day to drive transparency and accountability
MI shared weekly with key stakeholders
Leverage all weekly governance forums to ensure rapid decision making and issues resolution
Leverage all control mechanisms in place to ensure issues and risk are mitigated
On-going training and upskilling. Training is not a one time event – it is the ongoing skill development of the Ops Team which is critical.
Op. Model Standardisation
Define the target operating model to which the project team will align. This will ensure there is one standardised method of operation flowing through the project and a blue print for faultless delivery and operational excellence.
Key dimensions of the Op model may include:
Appropriate reporting should be in place to monitor and manage production schedules and SLAs. Governance should be established to oversee performance and facilitate rapid decision-making and issue resolution.
KYC remediation projects succeed primarily because of early engagement of key stakeholders, the iterative development of remediation standards and the continuous confirmation of risk issues, risk appetite and ownership of files moving to BAU at file sign-off.
MI is critical to measure and communicate progress as well as to identify common problem areas that may yield opportunities for continuous improvement.
•Events: tracking of events ( SLAs / Quality)
•People: individual and/or team performance and/or measuring communication of issues requiring management attention (analysts failing to hit the required standard)
•Systems: efficiency of software and tracking of “downtime” (is the KYC system actually fit-for-purpose? How is downtime affecting performance?)
•Processes: identifying bottlenecks, touchpoints or aging of cases.
•Productivity: assessment on team productivity and a measure of how this tracks to plan.
A successful project needs an effective controls structure and intense rigour to ensure risks and issues are mitigated. We have listed four key controls below:
Quality: Right First Time & Upskill
Quality Metrics provide a quantitative way to measure performance and should be reported internally and externally on a weekly basis
Balanced approach by calibrating sampling based on performance
Workshops to be set-up with designated SMEs if knowledge gaps appear
Weekly Triage sessions with arbitration process built-in as necessary.
Backlogs: Non- responsive Clients & Front office
Build in robust mechanisms to avoid and reduce backlogs
Together with the business, design and enforce a notice to close process with clear consequences for non-return of KYC documentation. [For example, after 30-day period case moves to DNT]
Weekly forums held with Compliance to provide risk acceptance on problematic cases
Weekly forums held with Front office business managers to highlight non-responsive clients and provide resolution.
SLAs: Coordination and enforcement
SLAs to be agreed with key business functions including Compliance, FO, QA, Tech. This will set a clear, measurable standard of performance
Leadership to monitor SLAs very carefully and report on a weekly basis via targeted MI if SLAs are being adhered to. If SLAs are being broken this must be raised and escalated immediately.
Output: Managing throughput expectation
Tight controls should be in place to ensure the client has full visibility on the teams remediation efforts at all times
Including stakeholders in critical communications, inviting them to join troubleshooting forums and workshops designed to improve output is key to managing client perception
MI needs to be robust and tell a compelling story behind the work-productivity- throughput journey.
Ensure the Target Operating model is robust and fit-for-purpose before investing in Tech.
•Consider the expanded use of KYC digital solutions, such as artificial intelligence and automation to reduce the time and cost of KYC operations.
•Automate the gathering of personal information, nature of business and business type via third party providers. Use an intelligent rules engine combined with API connectivity to data sources to automate verification of data and docs during the on-boarding process which comply with internal policy.
•Use an intelligent rules engine combined with API connectivity to listen for material changes in client circumstance/risk rating and react in real time. Third party providers, such as iMETA, can automate the COB process and provide an intelligent rules engine that drives behaviour, guiding and directing the analyst through the end2end process.
How to Effectively leverage Front Office
-Upfront client analysis to bring associated and grouped clients in-line with one another at the point of refresh.
Benefit: Reduction in the amount of screening. Reduction in the effort required to obtain KYC documents. Streamlined client contact.
-Agree a rejection / notice to close process with Front office to ensure return documentation or account closure.
Benefit: This will help to erode backlogs and focus resource purely on the engaged clients.
-FO own the relationship but are not necessarily KYC experts. Regular upskilling and training should be provided to FO on the fundamentals of KYC.
Benefit: Bridge knowledge gaps and keep FO up-to-date with all pertinent changes to policy and process and general KYC requirements.
-Appointing designated FO heads from each business line to take personal responsibility for requests and return documentation.
Benefit: Improved engagement and collaboration will help to ramp up productivity.