Customer: UK tier 2 bank
Industry: Retail banking
Use case: BWRA, horizon scanning, financial crime knowledge management
Outcomes: Defensibility, saved time and resources
A United Kingdom-based bank that offers a range of retail products, including travel money, credit cards, savings, and loans, had a strong anti-financial crime program in place prior to using the Acuminor’s platform Risk Assessment Pro (RA Pro). But they wanted to ensure that they were taking an objective view of their risk and could quantify that risk to internal stakeholders and regulators.
Here’s how they implemented a technology-enabled intelligence solution that lets them defend their rationale and decision-making to regulators, while unlocking productivity gains.
The danger of what you don’t know
The AML team consisted of four people that had been working together for a few years. Although they had robust horizon scanning processes the Head of AML worried that they might fall victim to groupthink when it comes to assessing the threats and risks that their business was exposed to.
“When it comes to horizon scanning, there’s always the risk of what you don’t know. Of not interpreting things in the right way and becoming too comfortable with being a UK-based bank.”
Head of AML and Deputy MLRO
They needed a way to ensure that they’re accurately assessing threats and putting the right measures in place, so that if they were ever approached by the regulator, they’d be able to demonstrate the effectiveness of their program with confidence. He worried that by not having their own findings validated by a third party, they were potentially opening themselves up to large fines.
The four members of the team were also responsible for producing the firm-wide risk assessment.
“We were using an excel-based solution and applying our own judgment. If you do that incorrectly, you’re leaving yourself open to getting fined by the regulator. You're basically marking your own homework.”
Head of AML and Deputy MLRO
The risk assessment process involved looking at FATF guidance and all relevant regulations, then gathering data from the rest of the business, which was a labour and time intensive task. They’d then put together a scoring mechanism for their inherent risk, the impact of their controls, and their resulting residual risk, and attribute the risks to each product and customer segment.
Despite the amount of time and resources spent on this exercise, the Head of AML thought it was too open to interpretation:
“We had a good tool that was built in house, but if you think a control is a five, when in reality it’s only a three out of five, you’re in trouble”.
Implementing an objective second layer of intelligence
By implementing the Acuminor’s RA Pro, they now have access to an objective source of information that they use to verify or change the way they approach risk in the business.
“Acuminor is a secondary source of information that lets us rationalize the decisions we make. Without that, you could be 40% off, and risk not quantifying your threats appropriately”.
Head of AML and Deputy MLRO
The platform combines the expertise of law enforcement and financial crime specialists with technology, to show them the threats that are relevant to their organization. It also provides them with valuable definitions that they’ve used to build out their processes internally.
They’ve been able to use those definitions in transaction monitoring reviews, a function that they’ve outsourced. They use the platform definitions as part of the training and oversight of the agents that work with alerts, giving them as much detail as possible on what they need to look out for in each scenario.
“Acuminor has given us valuable definitions which we’ve used to build up our processes internally. It makes it easier to quantify our risks and summarize our work for senior management.”
Head of AML and Deputy MLRO
In addition to simplifying the risk assessment process, saving time and money, the platform gives them an objective way to quantify their risks, and communicate these to stakeholders throughout the institution.
As part of their onboarding, Acuminor provided in-depth training on how to set up and use the platform and helped them through completing their first iteration of the risk assessment using the solution. They found the platform intuitive to use, and the team got up to speed quickly.
Evidence-based decision-making and increased productivity
By using the Acuminor’s technology, the bank’s been able to:
- Save time and money by not having to employ an additional person to do research on guidelines and recommendations.
- Use definitions across the business and with their outsourcing partners.
- Have an additional layer of intelligence against which to measure and quantify the risks they’re exposed to.
- Defend their financial crime program and any changes they make.
“By using the Acuminor platform, we’re saving time and resources. We’re able to back up our decisions and ensure that we’re focussing our resources on the right areas. We wouldn’t want to go back to the old way”.
Head of AML and Deputy MLRO
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