Enhancing a client’s processes whilst addressing a growing backlog of potentially risky customer accounts

The client approached Nexus AML with a request to overhaul their financial crime prevention programme, which had fallen behind on its file completions. Nexus AML provided a consultancy service to develop the client’s high-level functions to bolster their financial crime defence.

Our team integrated within the client’s compliance structure at the head of Financial Crime/ AML, reporting directly to the MLRO.

Providing advice

on all Anti-money Laundering

(AML)/ Fincrime

escalations for 1st line

and 2nd line of

defence

Leading multiple

internal projects

including an Enhanced

Due Diligence (EDD) backlog, internal monitoring,

and others

Review processes and create

Provide guidance on

new product

proposals and

policies.

Manage a screening backlog and provide support to Nexus AML

analysts working

through the backlog

Challenge

A key challenge for this project was the depth of tasks that required immediate attention. The inefficiencies in the process that led to an increasing backlog of incomplete files needed to be addressed with short-term fixes to reduce the workload.

Upon further review of the client’s documentation, many processes and policies were not up to date and required a complete, time-sensitive redesign. These policies and documentation directly.

impacted the AML framework for the client, meaning this was a high priority. This included a comprehensive Customer Due Diligence (CDD) handbook which could be used universally across all internal teams. The client requested an improved screening manual, and a complete overhaul of the internal monitoring process.

A large-scale challenge was to bring the client’s internal monitoring and EDD backlog up to

date. The client was 3 months behind schedule due to this stockpile. The screening backlog

was one of the key areas which Nexus AML were tasked with reducing, however the sheer number of

screening hits made this a difficult challenge.

Solution

To overcome the challenge of overcoming

several tasks simultaneously, we took some

actions early in the project to help understand

the client’s risk appetite. As the main point of

contact for all edge cases and AML escalations,

our expert’s understanding was key to

providing the best advice. This gave Nexus AML the opportunity to understand what the current

risk-based approach was when it came to

escalations and edge cases.

Regarding the documentation updating, early in

the project, our expert familiarised themselves

with the current AML/Fincrime policies and

procedures. We quickly identified that there were several documents that needed uplifting. After

liaising with the Money Laundering Reporting

Officer (MLRO) and Head of Operations, Nexus AML and the client agreed to focus attention on the internal monitoring documentation and process.

Our team embedded themselves within the compliance team who were performing monitoring to specify the areas which were being reviewed and adjudged to receive a pass/fail outcome. This enabled us to create an internal monitoring checklist which covered all areas (AML/Onboarding, Direct Debit Change and Fuzzy Logic Queue) alongside a process document which clearly explained what was being checked and the pass criteria.

To address the screening issues, Nexus AML leveraged our operational experience working with various screening tools and processes to enhance the manual. The MLRO requested a robust discounting framework in addition to the manual so that anyone reading it could get a decent understanding of how and when to discount false positive hits.

Outcome

Nexus AML successfully delivered on multiple fronts, comfortable achieving client expectations.

Specifically, reducing the EDD and internal monitoring backlog and bringing it up to date.

By using Nexus AML and client resources, we were able to plan and manage priorities to ensure we

delivered to the highest standard.