Pilot roll out ensures Regulatory Requirements are met in a a controlled and consistent implementation.
The Situation
In a regulatory environment, banks need to strive for continuous improvement and continue to reduce the risk of Financial Crime whenever and whereever possible. Programmes fail due to an attempt to implement perfect 100% solution from day one. Although it makes sense to implement the best most comprehensive solution at the first go, due to time pressures this is hardly ever possible.
One of my major Global Banking client was under a lot of such pressure from a Deferred Prosecution Order to reduce immediate risk by implementing TM Optimisation & also to create a more sustainable TM Framework for the future.
The Task
I had to implement a Transaction Monitoring Optimisation Programme without an agreed methodology or agreed qualitative standard/baseline due to the time pressure applicable. In addition to quality, consistency between countries of the same bank is also extremely important to show regulators there is global control.
The Action / Approach
I used 3 countries as pilots (Canada, UK and Mexico) to allow to manage changes in the draft process of optimising the systems, processes and people.
To manage high standard & consistent optimisation methodology roll out, I planned to baseline the pilot version from our 3 roll outs before updating/re-baselining this again for the next 5 and so forth. This allowed for the creation of global consistency and for the Programme to manage further ‘upgrades’ in tranches in a controlled manner.
I also involved the internal testing teams at this stage to advise on any possible improvements we could use to enhance further versions of the methodology.
From the pilot I identified the lack of the correct use of the methodology and stakeholder buy-in as a major threat to a quality optimisation. I created a ‘kick off’ pack for each jurisdiction, ensuring the local stakeholders were aware of phased roll out & continuous improvement philosophy & implementation plan, instructions and guidelines for optimisation.
This was then followed up with on-site support and daily/weekly meetings as the implementation progressed.
The Result
The creation of the final 1st version of the methodology was achieved after the first three pilots so further implementation tranches were all in synch with a global consistent methodology and signed off by the internal testing teams and regulatory office.
