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
