AML/KYC Policy writing & design of Operational Procedures framework

Client Needs & Objectives

Following a recommendation from the Internal Audit, our client decided to write a new KYC policy, to align with the group, and to address the audit recommendation

The objectives were threefold:

  • Produce a new KYC Framework, aligned with the Group KYC Policy and amend/update the related operational procedures for the KYC teams
  • Define the planning and roadmap for the implementation of new regulatory measures
  • Optimize the structuration of the operational procedures implementing the KYC Policy

Our approach

  • Update of the CIB KYC policy: gap analysis between CIB and group policies, definition of the policy timetable and structure, definition of KYC-related criteria by types of clients, products or countries and local responsibilities and specificities, implementation of a dedicated Governance, clarification of the roles and duties
  • Procedures writing and update: impact studies on workflows and KYC IT systems, clarification of priorities between CIB instructions and local specificities, update of existing KYC checklist by client types/ products, workshop and writing of operational procedures
  • Target procedures structure: benchmark the different in-house tools according to the key criteria (User-friendliness, Storage capacity etc.), draft of the decision file to select the tool (if any) including budget and planning and of the business requirements

Client Benefits & Main Results

  • New KYC policy validated across the board

  • Adapted and comprehensive operational procedures

  • Clear governance defined in monitoring, maintenance and update of procedures

  • Updated process for procedures and related IT solution selected and implemented

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