Background
A global bank faced remediation requirements mandated by federal and state regulators that involved a “cease and desist” order for particular lines of business. In this instance, the regulator required the appointment of an Independent Consultant (IC) to conduct an annual 90-day OFAC Compliance Review, which included a review of OFAC compliance policies and procedures and appropriate risk-focused sampling of USD payments.
In the context of the IC review, the global bank requested Wavestone’s assistance in preparing for the arrival of the IC, providing ongoing support during the IC’s 90-day assessment, and debriefing on activities after the IC concludes its assessment.
Challenges
Wavestone helped the client address the following challenges:
- Developing a governance framework for IC interaction – The bank enlisted Wavestone to manage the logistics of the IC review across multiple international locations. Wavestone defined, validated, and implemented a governance structure for the Independent Consulting review period, while managing, planning, and coordinating the IC’s inquiries, the bank’s responses, and the debriefings.
- Managing document repositories and developing process controls – Wavestone developed a 6-eye control process for managing the IC document repository to ensure that the appropriate documents are communicated to the IC. Wavestone also monitored the delivery of documents to facilitate responses to IC inquiries. To ensure the smoothness of the review process, Wavestone also conducted team training with key contacts within each client team.
Answers and Key Success Factors
- Established an efficient workflow to facilitate the review of IC documentation
- Aligned governance structure with the existing Executive Committee set-up to enable seamless communication with the IC
- Created an effective communication plan enabling active participation from all levels of staff involved with the IC review
