Real-time quality assurance review of customer onboarding for an international bank

Our client was an International Bank whose services included Corporate Banking, Institutional/Correspondent Banking and Private Banking.

In the years prior to our engagement the Bank had been subject to a multi-stage Skilled Person review with a focus on Financial Crime. They had successfully exited this process but in a subsequent sample review of their Client Files they found that some areas of weakness were emerging. As a remediation step the Firm self-imposed the introduction of an independent third party Quality Assurance review as part of their onboarding process.

Our work consisted of undertaking a Quality Assurance review of each new client application prior to contractual onboarding.

For each client application our Financial Crime team reviewed and assessed for evidence of:
• Compliance with Policy and Procedure content standards and relevant regulations;
• Clear and accurate application of a Customer Risk Assessment;
• Appropriate levels of CDD and EDD (including Source of Wealth and Funds);
• Evidence of PEP, Sanctions and Adverse Media screening, discounting and escalation as appropriate;
• Evidence of escalations / waivers if required;
• Appropriate levels of management approval / sign off.

Our team identified any exceptions as they arose and evaluated completion prior to signing off the file.

Given the real-time nature of the engagement and the importance of expediency we maintained a core review and QA team so that we could respond quickly and maintain a 48-hour service level agreement for review time. To date we haave reviewed in excess of 100 customer files relating to Corporate, Individual and Corresponding Banking relationships.

We provided the Firm with ongoing feedback so they could make timely enhancements during the engagement and provided the enhanced assurance required over their onboarding.