The first task was helping the bank establish and document risk-based standards that could be used to identify the customer population to be reviewed. Among other steps, PwC obtained and analyzed transaction data to verify that customers in high-risk categories were included in the population to be reviewed and developed a workflow tool to improve quality and efficiency. When it became apparent that the bank’s relationship managers were not completing the required Know-Your-Customer reports in a timely manner, PwC also designed and implemented a pilot training program to enable bank personnel to meet these requirements more effectively—by the regulator's deadline, as well as on an ongoing basis.
Since the initial customer review process had been highly manual, the bank needed to revise its approach and define a strategy that would enable them to complete the tasks required by the
regulators within the established timeframe. Drawing on a broad range of PwC resources in governance, risk management, compliance, and data management, PwC helped the bank develop
and obtain approval from regulators for a streamlined initiative.
By automating analysis of high-risk transaction activity, the team was able to significantly decrease the size of the population requiring
review.
Moreover, with PwC's assistance, management was able to secure the regulators’ approval to reduce the review period from one to two years to just 15 months. The introduction of automation also enhanced the effectiveness and accuracy of the bank’s targeting process for identifying high-risk customers, improved the quality of documentation, and increased control over file and customer tracking.
Throughout this process, PwC played a crucial role in assisting management in the establishment of quality control procedures under significant deadline pressure.
