An agile AML remediation function for fast time-to-success

Sizable fines, steep civil penalties, and reputational damage — our client knew these were the risks of not complying with increasingly tough AML and KYC regulations. But cleaning up these capabilities meant fixing multiple issues.

The client needed to correct deficiencies that the regulatory authorities had identified, but it didn’t have enough talent with the necessary knowledge of ever-changing AML requirements, customer onboarding, and alert remediation, or compliance monitoring, surveillance, and testing.

• Operations in the Americas, Europe, and Asia Pacific had different ways of determining and handling false, potential, and positive matches. The regions also used different remediation processes
• The company didn’t have rule-based systems to provide real-time visibility into the triggers behind its high rate of false positives
• There was limited integration across the company’s multiple data sources
• The company needed to acquire and retain the right customers

Recognizing its shortfalls, the company partnered with Genpact to take advantage of our AML and KYC domain and process expertise, technology, tools, and global delivery capabilities.

After assessing the client’s existing compliance function to get a 360° view of the current state, we used the global talent, digital technologies, and process expertise in our AML center of excellence (CoE) to create a virtual captive operation to handle the client’s AML/KYC needs.

Capabilities we’re delivering through the virtual captive include:

Standardization across regions

Whether serving the Americas, Europe, or Asia Pacific, all the team members are now using the same best-practices-based processes and documentation, which eliminates monitoring, surveillance, audit trail, testing, and reporting inconsistencies.

Insights driven by digital and analytics

We implemented a transaction monitoring system to generate alerts for suspicious activities. The new system collects data from structured and unstructured sources, normalizes the data, and generates alert reports for potentially suspicious activities based on large amounts of scenarios and thresholds. With the new transaction monitoring system, team members can screen, mine, and extract all available transaction data in near real time, making it easy to analyze the data for risk leakage and red flags.

Seed teams and training

To make sure we delivered quick wins to the client, we began with a seed team of AML and KYC experts to handle important roles including pilot batches, quality control, project management, and client onboarding. And our seed team used a train-the-trainer model to make sure the growing front- and back-office team was consistently and fully trained to continue delivering successes.

By proactively partnering with us, this financial firm cleaned up its AML and KYC functions before regulatory non-compliance became a pricy problem. The results we’ve delivered through our virtual captive solution include:

• Fast time-to-success with our highly skilled resources and enterprise-wide, best practices-based processes
• Cost-effective and consistent client onboarding and training
• Better visibility and understanding of the risk profiles of customers and their external counterparties
• Agility, scalability, reduced risks and errors, and timely, data-informed decisions