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.

With no immediate fix available to meet the unplanned CBR requirements It was my job to present options to the Steering Committee.

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:

1. Modify the legacy system (Norkom = expensive, slow and lost investment)
2. Use the new strategic investment (Mantas) = part of the suite in the new system but implementation was not planned for next year.
3. Develop code ourselves outside system landscape for this scenario (could be done, fast & cheap but carried risk of maintenance cost and failure) – RECOMMENDED
4. 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.

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.

• creative problem-solving
• Option Appraisals
• stakeholder management
• Stakeholder Engagement

• BI & Analytics
• Process Effectiveness & Automation
• Organisational Agility & Effectiveness
• Purpose to Portfolio