AML Remediation Program

SUMMARY

A bank requested the engagement of Avantage Reply in August 2019 to support them with the implementation of the AML action plan and the recommendations imposed by the supervisory authority for the implementation of AML regulations within the Belgium financial sector.

Avantage Reply's consultants supported the development and implementation of internal processes using a risk-based approach, a client file review and transaction monitoring analysis. In particular, Avantage Reply's consultants were positioned to work as Compliance Analysts and Quality Reviewers dealing with files and bank accounts on private and institutional entities. Avantage Reply's successful results and dedicated efficiency, has seen the client ask for additional support in other areas of its business.

CUSTOMERS GOALS

The Client wanted to develop an action plan according to the project findings and the report to the supervisory authority that followed after the Client inspection. The goal of the Client was, within the tight timeframe specified, to successfully implement the actions and recommendations enacted by supervisory authority through its report.

THE CHALLENGE

The Client, pursuant to regulatory and legal requirements is required, among other things, to implement a series of measures for an appropriate risk-based approach on the following;

• Acceptance procedure and on-boarding of new clients and assess relationship with existing clients;
• To produce Risk and AML assessments;
• To systematically monitor for atypical transactions and perform adequate vigilance for transfers from abroad;
• To perform adequate client file analysis and Client File Review (CFR)

Avantage Reply was not the only consultancy firm engaged to support the Client to succeed its requirements and reach the deadlines given by the supervisory authority. Nevertheless, the co-operation with the other consultants involved was managed smoothly, allowing for constructive team synergies.

Avantage Reply often deals with complex and challenging situations when performing their work efficiently, in order to reach the tight deadlines specified by the client. The complexity is, in certain situations, created as a consequence of the internal and organizational processes that are usually being modified to satisfy the client’s needs.

APPROACH AND SOLUTION

Avantage Reply engaged its experienced consultants in the financial crime and anti-money laundering compliance fields to support the client in performing the Client File Review and transactional monitoring on private and institutional clients. The consultants were engaged as follows:

• The Fast Track (or Ex Ante) team was needed to perform the CFR on the request of the private bankers. The team needed to act fast to complete the CFR with the client’s account only being unlocked once the CFR was done;
• The Ex Post team also needed to perform the CFR on the request of the private bankers. The difference with the Fast Track team however, was that the client’s account is unlocked before performing the CFR, on the condition that the CFR is done within one month after the unlocking of the client’s account.

The QRs were responsible for reviewing the files prepared by compliance analysts, raising any points that need further investigation, examining any tax implications and making their view on the analysis. The file will then be presented by QRs to the Client committee to unblock the bank accounts of the respective client.