Background
Some of a Foreign Banking Organization’s entities were banned from clearing in USD for specific activities through its New York branch for an entire calendar year. The bank engaged Wavestone to create a work plan and shared methodology to prepare for the ban on a global scale under significant time constraints and heavy regulatory pressure.
Challenges
Wavestone helped the client address the following challenges:
- Defining the project governance and approach – Wavestone defined the approach and methodology for preparing the FBO for the ban on a global scale then deployed specifically-tailored toolkits to ensure the project’s success. More specifically, Wavestone defined and communicated the roadmap of the ITO stream while reviewing both deliverable quality and conformity during the entire delivery cycle.
- Monitoring the project and coordinating the implementation phase – Wavestone organized an implementation plan with stakeholders, assisting the FBO during kick-offs, key meetings, and the deliverable validation. As the project progressed, Wavestone monitored its progress and deliverables, assessing scope extensions and arbitrating when necessary.
- Defining the framework and testing the strategy – At the start of the engagement, Wavestone documented the current set-up of USD payments to provide an accurate and comprehensive assessment of the scope. Wavestone contributed to the definition of the control framework for banned entities, performed Proofs of Concept, and organized both the test phase and the go-live. Prior to the implementation of the finalized filtering solution, Wavestone formalized and validated the target processes with their respective owners.
Answers and Key Success Factors
- Implemented the payment filtering control framework ahead of the scheduled go-live date
- Created an effective organization to stop, escalate, and process necessary payments in accordance with the ban
- Monitored daily payment activity post go-live and refined controls and procedures, as needed
