Background
In response to a large financial sanctions violation, a global bank was required to develop a remediation plan to prevent future misconduct. As part of this remediation plan to strengthen compliance with financial sanctions, a global bank requested Wavestone to define a program governance structure, perform an as-is analysis of current sanctions risk controls, identify control gaps, and define a global risk control framework to remediate the gaps and enhance the bank’s controls on USD products and processes of the Corporate & Investment Banking (CIB) business lines in the Americas.
Challenges
Wavestone helped the client address the following challenges:
- Global coordination and alignment – Facilitate communication and enforce collaborative behaviors across EMEA, Asia, and the Americas to foster balanced governance, common understanding, consistency in solution design, and knowledge-sharing
- Scope assessment and diagnosis for CIB business lines across multiple locations – Determine the complete scope of CIB products / business processes – in particular, regional specificities that could diverge from the “pilot” risk control framework defined by EMEA
- Holistic solution design – Mobilize stakeholders across the business and functions to define robust solutions for addressing the bank’s control gaps, reinforcing a holistic, front-to-back vision in adherence with the framework’s requirements
Answers and Key Success Factors
- Driving effective cross-collaboration, implementation synergies, and seamless alignment across regions, particularly for common global issues (e.g. screening)
- Setting up an effective project structure to engage, communicate, and validate solutions with stakeholders from the Front, Middle, and Back offices. Our cross-functional interaction model enabled us to enrich solution design discussions and reinforce a holistic, front-to-back vision.
- Structuring solutions into projects and defining a detailed implementation plan with owners, deadlines, dependencies, budget, and resource requirements for each project
- Incorporating change management into the implementation planning process through an impact assessment of other Compliance programs in the bank.
