Hotscan licences were needed for Sanctions look-ups introduced by new Operating Manuals for all First Line KYC and Due Diligence teams.  However, Software, nor a new operating model were part of the Global Programme scope but a hard dependency on the regional BAU team to organise.

Three weeks before Go Live and after Operating Manual sign off and completion of all the training the regional sanctions head queried the number of user name based licences and was instructed by Head Office to minimise expenditure.   My team had kept the regional Sanctions team abreast of the licence requirements throughout the Programme with regular updates and meetings.

The local operations team had already expressed ‘displeasure’ at learning about a possible licence restriction so late in the day as the Programme had updated the Region of licence requirements and only applied for the additional licences to the region a week before.  Pressure to save money from the Region was also very strong coming from Head office in Tokyo.   The task in hand was to create a workable solution for the Operations team whilst satisfying the late drive to save costs.

I executed analysis on the licence arrangements and usage and called a meeting with Operations, the Programme and Regional BAU teams and set out the options:

1. Negotiate licences based on # of look ups or unnamed  – I did this in a previous Programme with Worldcheck and saved Euro 1.3M – however, there was no time to pursue this now.
2. Amend the Operating Model and create a central team to execute the look-ups and adjust the Operating Manuals to request names.  Only this central team needs the licences and can send a PDF to the local requestor.  This was the preferred option for the region BUT to execute this plan would need a re-write and sign-off of procedures, as well as Data Protection Officer/lead approvals. for which there was no time.
3. I talked one to one with all the local Fin crime officers to ask to re-assess the local requirements and come up with a local stream lined use of sharing licences (they are name based)
   • Using data of past usage
   • Risk based assessment of what needs to be used
4. Bite the bullet and pay for the additional licences (11 in Amsterdam & 17 in Dusseldorf).

Using the data collected for all the options, it motivated the local FinCrime officers to ‘dig deep’ and suggest short term licences reductions which they could make workable for a the immediate months after Go Live allowing us to move forward.

In the meantime, I helped the BAU to create a plan to set up a central look up function for jurisdictions and customer types that would allow data to be passed cross border.

The suggestion to re-negotiate the poor licence agreement was passed to Tokyo procurement team and negotiations were still ongoing by the time I left the bank.

• Business & Operational Analysis
• creative problem-solving
• Team Leadership
• Commercial Management

• Organisational Agility & Effectiveness