Thorough analysis of available options allows for a creative solution to Regulatory conundrum
The Situation
At my Global Investment Bank Client as Regional Programme Manager for EMEA Financial Crime Analytics & Intelligence (Transaction Monitoring analysis), I was responsible for the implementation of a new strategic framework as well as tactical solutions.
In the Russian entity there was an unplanned gap in Central Bank of Russia (CBR) monitoring requirements that had a hard deadline for on-site regulatory visit.
The Task
With no immediate fix available to meet the unplanned CBR requirements It was my job to present options to the Steering Committee.
The Action / Approach
Having identified the requirements for the regulatory monitoring (tax payments), my analytics team established that no such scenario was covered in the current legacy system.
I lead the team to pull together all relevant information and data on the requirement and solutions and came up with 4 options:
- Modify the legacy system (Norkom = expensive, slow and lost investment)
- Use the new strategic investment (Mantas) = part of the suite in the new system but implementation was not planned for next year.
- Develop code ourselves outside system landscape for this scenario (could be done, fast & cheap but carried risk of maintenance cost and failure) – RECOMMENDED
- Monitor manually (labour intensive, high risk of missing alerts/errors and not Regulatory preference)
I presented the options with associated volume, risk, cost and time data to the Steerco and recommended option C. with a long term solution of option B.
The Result
Outcome:
- Steerco requested confirmation from Russian CEO of the Regulatory requirement – evidence was presented of the regulator request which I could not obtain.
- Steerco also enquired with Global AFC if the mantas strategic implementation could be pulled forward – this was not possible as already established.
- I also investigated why the request was a surprise and to avoid this from happening again, a Global Compliance Reg Office was set up to track ALL requirements and remediations.
- Option C was taken forward and successfully delivered and approved by internal audit and the CBR.
