Japanese Investment Bank - KYC Programme

28/11/18

Client Issue

Our client, a global investment bank, was experiencing significant regulatory pressure with the ongoing management of its Know Your Customer (KYC) population. The client had allowed a backlog to develop with their KYC population and this backlog was building as more cases needed KYC refresh under the usual cycle.

PwC was engaged to provide additional support to our client's compliance team to address this KYC backlog. A team of around 100 staff was set up in our delivery centre in Belfast, working with a senior team based in London. This team worked as part of an overall client programme that included a client team in London and a new site that had been established in India.

PwC Approach

PwC stood up a large team over a six week period consisting of 66 KYC Analysts, 18 QCs, four team leads, four KYC subject matter experts, a data analytics and MI team, a programme office in Belfast and programme support in London. The analysts, quality controllers and team leads were organised across six KYC cells, which were supported by the subject matter experts and the programme offices.

The Belfast team worked collaboratively with the overall client programme management team and delivery teams in London and India to address the KYC backlog and files coming up for periodic refresh.

PwC’s specific responsibilities included:

  • Establishing programme governance
  • Reviewing and helping to finalise the client KYC policies and procedures
  • Developing training materials for use with the Belfast teams and with the newly established capability in India
  • Developing the capacity planning model and plans for each site
  • Completing KYC cases including analysis and quality control checking before submission to the client Financial Crime Team for final review and sign off
  • Used our bespoke RADAR research platform to both verify the client’s existing information and fill in any missing gaps
  • Generation of all reporting and MI
  • Supporting the programme cadence contributing to the regular Working Groups and Steering Committee meetings

Our team of AML experts also assisted the bank’s senior management to help them understand the risk profile of cases to aid their conversations with the local regulator.

Outcome & Benefit to Client

PwC is in the process of completing a review of approximately 2,500 client files, mostly High and High Focus risk classification. The additional surge capacity enabled the client meet the commitments that they had made to the FCA on timescales for remediating the backlog population and ensuring that a backlog did not start to.

Contact us

Stuart Croft

Stuart Croft

Director, FinCrime Operations, PwC United Kingdom

Tel: +44 (0)7713 793612

Follow us