Client Top 5 Bank

Industries Banking + Financial Services

Services Risk + Compliance

Challenge

One of the nation’s top 5 banks received a consent order from the United States Office of the Comptroller of the Currency (OCC) requiring them to improve their Bank Secrecy Act/Anti-Money Laundering (BSA/AML) program. As the bank began remediation of over 300,000 customers, they wanted to develop, communicate, and implement standard processes. Each of their 23 Lines of Business (LOB) had slightly different business models, systems, vendor teams, and organizational structures, which made standardization difficult. In addition, the large size of the project made internal communication a challenge. They needed to create a centralized middle office to serve as an intermediary to help solve these issues.

Results

The bank established and maintained a customer due diligence program up to regulatory standards to fulfill the consent order. Additionally, the Middle Office helped the bank more efficiently remediate the required customers, resolving over 3,500 issues and processing over 18,500 special cases, through:

  • Centralized issue management
  • Increased awareness of remediation risks and issues, which allowed for more informed decisions
  • LOB awareness of program directives, which aided in implementation
  • Standardized execution across the program, which increased operational throughput

3,500

Issues Resolved

18,500

Special Cases Processed

Finding the Middle

The Middle Office sits between the remediation team, the LOBs, and the vendors to centralize processes, bridge gaps in communication, and identify and remove remediation roadblocks. We used the delivery-center approach to minimize use of the client space, reduce travel costs, and onboard resources in a short period of time. The project consisted of the following teams:

Our Process

LOB Support Team

  • Assisted in LOB/vendor production oversight by facilitating production meetings, generating daily production overviews customized to the needs of the group, communicating deadlines, and identifying and mitigating LOB-specific bottlenecks – all leading to increased productivity
  • Segmented each LOB’s customer population to strategically identify resources and timelines for remediating each sub-population
  • Trained LOB partners on tools, reporting, and processes that would be utilized after remediation, empowering them to complete future analysis and issue resolution
  • Served as the first escalation point (Tier I) for issues that could not be resolved by the LOB/vendor teams, researching and resolving issues if possible
  • Escalated larger or more complex issues to the centralized Escalated Issue Resolution/Communication Teams (Tier II) or Round Table (Tier III)

Centralized Process Team

  • Determined the most efficient processes for managing complex cases, including customers with multiple LOB relationships, foreign customers, special customer types, mergers, and customers excluded from remediation
  • Designed and implemented a process for completing high-risk determination assessments for customers with certain high-risk attributes, and provided corresponding training and reporting
  • Executed processes in a single centralized team to ensure consistent treatment of complex cases across LOBs and improve record keeping, aiding in making population-management decisions

Escalated Issue Resolution/Efficiency and Communication Team

  • Researched, escalated, and resolved issues that involved more complex subject matter or affected multiple LOBs (Tier II)
  • Created a centralized knowledge repository utilizing Confluence software to enable sharing of information throughout the Middle Office and across LOBs/vendors
  • Increased efficiency by monitoring program-wide processes to find bottlenecks, performing root-cause analysis, and working with shared services on process improvement (including screening & verification and others)
  • Implemented centralized reporting on the most challenging customer cases in each population and managed LOB/vendor remediation teams to drive completion in advance of regulatory deadlines