SME as a Service
Financial Crime Unit (FCU) at PwC Poland provides a specialised support of Financial Crime Specialists (SMEs - Subject Matter Experts) to the 1st Line of Defence (1LoD) Know Your Customer, Transaction Monitoring and Sanctions programs.
FCU Policy & Compliance stream competencies and availability of 80+ SMEs are a remedy to the growing need for experienced, knowledgeable personnel that may support efficient delivery of ad hoc projects, day to day processes and holistic cooperation under managed service offerring.
Financial Institutions experience increasing number of obstacles affecting Anti-Financial Crime (AFC) programs and processes execution efficiency:
- [Execution] Inconsistent approaches or delays due to differing interpretations of policies and procedures
- [Direction] Unclear translation of policies, procedures and requirements into operational guidance
- [Production] Frequent "bottlenecks", permanent on-holds and inconsistent waivers & deviations
Discover the possibilities of the SME as a service support
Execution
- Liaison between 1st and 2nd LoD stakeholders (escalation management)
- Process and procedural change agent
- Expert advisory to process execution
Tools & Instructions
- Implementation of AML requirements, process and operational desk-top procedures
- Validation and design of operational tools
Quality
- Execution and oversight of existing quality framework - measuring and reporting quality of operational units, root-cause analysis
- Feedback loop, remediation and progress monitoring
Testing
- Controls design & testing of process steps and execution
- Validation of new and existing tools & processes
Training
- Diagnosis of training demands and development of training materials
- Training delivery and knowledge assessment
Benefits
SME as a Service - Capabilities focus
The degree and nature of services, delivered by FCU Policy & Compliance stream experts, can vary depending on the specific needs of the customer. Versatility and flexibility ensures efficient engagement in a broad scope of tasks, providing support and expertise over the entire AFC programme execution (incl. large-scale operations programmes).
Extensive professional experience in AML/CTF areas (both practical and theoretical)
Hands-on experience in the design of and the execution of KYC and TM activities for Financial Institutions
Synergy between Operations and Compliance - unique insight into translation and operational execution of AML/CTF obligations
Certified experts in Financial Crime industry-wide recognized organisations (i.e. ACAMS, ICA)
Deep understanding of regulatory expectations, anticipating and embedding appropriate solutions in AML models
Holistic technical skills – fluent in tooling, process design & skilled in Policy and Procedure enhancements and implementation
How do we help our clients
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A Belgium branch of an international bank - CDD enhancement (KYC)
Project
Successful enhancement of 214k Client Due Diligence (CDD) profiles with various risk profiles and client typology including customer outreach.
Context
In response to a regulatory review, our Client launched a KYC enhancement programme and requested that PwC support with of over 214k client’s CDD profiles booked with their Belgian branch. FCU experts worked closely with our Client’s stakeholders (i.e. AML Excellence Centre) across multiple work streams.
PwC approach
FCU provided a full scope end-to-end design of remediation activities across different areas (from Policy to Technology, incl. KYC platform deployment and automations assessment). Team of FCU SMEs in partnership with the Bank Compliance developed procedural approach (incl. revisions), quality assessment modus operandi, training and acted as permanent liaison between large scale operations (500+ analysts) and 2nd line stakeholders.
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An International Bank - Politically Exposed Persons (PEP) remediation
Project
Financial Crime Unit (FCU) supported Bank’s transformation program by performing a review of PEP alerts generated from the Bank’s Wealth Management and Corporate clients portfolio under a tight and strict deadline.
Context
The Bank engaged PwC to perform an expert review of PEP alerts generated for its low and medium risk customers’ representatives, controllers and beneficial owner. Project included: i) Time & motion study, ii) Quality Control, iii) Management Information (MI), iv) Design of instructions manuals and v) Training curriculum.
PwC approach
In total PwC FCU completed 26,000 alerts (instead of 17,000 originally planned) within the same timeframe. Outcome: Refreshed PEP profiles and identification of circa 1,000 new PEPs.
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A Danish branch of International Bank - suspicious activity reporting (Transaction Monitoring)
Project
Support of MLRO function in management of suspicious activity detection & reporting.
Context
The Bank recognized a significant backlog of Unusual Activity Reports filed to MLRO and urgently needed to identify suspicious activity patterns. The Bank also required an interim solution for the transition of MLRO functions to a newly hired individual.
PwC approach
The aim of this project was to support MLRO in daily tasks and support the Bank in the transition period. FCU experts facilitated backlog resolution, suspicious activity patterns, scenario revision, SAR drafting and redesign of regular reporting to the FIU.
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A European Branch of a Russian Bank – real time screening (Sanctions)
Project
Review and evaluation of correspondent banking relationships between Eastern Europe, Western Europe and the USA. Project included AML investigators recommendations to the Bank regarding SAR or STR submissions.
Context
FCU experts supported the Financial Crime department in advisory & execution of sanctions and AML hits review in the real time transactions. The customer’s portfolio included sanctioned entities, hence the investigators needed to ensure sanctions compliant status.
PwC approach
On top of sanctions review and assessment the specific support extended to: delivery of training sessions, review of the internal procedures, implementation of 4-eye principle, addressing the deficiencies in audit findings.
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Large UK Bank - CDD processing (KYC)
Project
Large scale Customer Due Diligence (CDD) project to support the Client's BAU Operational team with standard and high risk customers profiles.
Context
Client identified regulatory weaknesses in their Customer Due Diligence processes, which led to the introduction of the CDD pathways framework. The Bank required additional FTEs to help maintain the compliance of standard and high risk, complex customer files within the Tactical In-Life Operations.
PwC approach
PwC FCU conducted non-personal CDD reviews on the Bank’s standard customers to ensure files are up-to-date and accurate ahead of transitioning to the strategic process. This project was mobilised during the global pandemic, meaning that operational quality work has been remotely monitored and supported by experts from the project inception.
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An International Bank - transaction monitoring sanity review (Transaction Monitoring)
Project
An International Bank engaged PwC in Transaction Monitoring project in order to investigate the activity of their branches in Baltics region.
Context
On the basis of instructions issued by the external counsel, the portfolio investigation work has been conducted by the Bank, together with 10+ experts from PwC.
PwC approach
The lookback and sanity review exercise focused on comprehensive review of customer KYC data, extended screening, transaction and activity assessment (including payment patterns), presentation of the recommendations to the Determination Working Group (external counsel & project MLRO) and draft of SARs ready for upload to FIU.
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