Updated: Nov 2
Many Financial services firms have invested $billions in meeting their Anti-Financial Crime and Client Lifecycle Management regulations. Despite all the investment, this is still rated as the most dysfunctional, highly penalised and operationally frustrating processes for customers, participants and regulators.
WHY IS THIS?
Approximately 6 to 10 years ago, under the scrutiny of regulatory enforcement, many banks were thrown into implementing more stringent requirements, remediating legacy data and documents and investing $billions in disjointed technology solutions – cycle 1, ‘achieve compliance’.
These firms are now much more compliant and have largely addressed historic compliance risks but find that their processes are still not scalable and customers are still frustrated by the way regulatory obligations are applied when they want to transact with their banks. Projected outcomes have only been partially delivered.
This stems from the original lack of a coherent end-to-end vision and underpinning architecture across AML and regulatory organisations, processes, technology and policy - the ‘rulebook’ that the other three pillars serve to deliver.
Banks are now finding their compliance/enforcement driven budgets have disappeared. Yet customers, regulators and shareholders all have expectations that current practices are falling short of. Regulatory, commercial and operational risk is starting to build again as remediated data becomes stale, customers become frustrated and promised benefits are not realised. Banks are looking to make bloated organisations more scalable and customer centric – cycle two ‘compliance & customer outcomes at scale'.
The solution is to break the cycle by defining a strategy that delivers real outcomes and then to mobilise the right team with real practical and transformational experience to overcome the organisational inertia to deliver results.
DOES ANYBODY DO THIS WELL?
The short answer is no. There is no one firm dealing with this level of complexity that has got all of this right. However, aggregate best practices across the industry include:
Single senior point of accountability for the four pillars at a global, cross business, outcome driven level
Clear orchestration of customer experience by a knowledgeable client facing team that can navigate the bank
Shared services for ‘utility’ type functions such as due diligence and client data, exits & screening, maximising reuse
Results driven transformational skill set accountable for scalability, protecting the bank, ROI and customer experience
Strong partnership among stakeholders such as Compliance, Financial Crime, Operations, Technology, Credit and Legal
Business outcome-driven model i.e., is the client Ready, Eligible & Configured to Transact the products they want in the regions they operate in?
Streamlined and harmonised policy, procedures and rules directly integrated into workflow
A ‘One Bank’ approach and standardised data model maximising standardisation, reuse, reliance across the Group
A deliberate end to end technology architecture that breaks down silos, selects the best system for the job and delivers incremental benefits often
Concise telemetry, insights and risk rails to measure performance, utilisation, pinch points and ensure transparency
WHY HAS NO ONE CRACKED IT?
Common themes across financial institutions include:
No coherent end to end vision and architecture: lack of an agreed blueprint across the four pillars of organisation, process, technology and policy underpinned by an economic framework.
The organisational model is not set up for success: the fundamental functional construct is inconsistent, duplicative, overlapping and there is no single leader to provide a coherent strategy.
Organisational inertia: there are too many stakeholders, competing priorities and people operating in silos, so the problem appears too big and fragmented.
Transformational skillset: there are limited real results driven change agents with the mandate to bring about transformational outcomes.
Other priorities: Budget and attention is prioritised elsewhere and the firm has become accustomed to ‘living with it’. The true scale of the problem is not really being quantified and is obfuscated by the ‘activity’ that is happening and the churn of the day-to-day BAU.
HOW CAN WE BREAK THROUGH THE INERTIA
1. Design the right Operating Model:
Establish the right operating model to set the organisation up for success and reduce the constraints caused by legacy ways of working.
Break down organisational silos and eliminate duplication that is a drag on scaling and achieving real performance across key indices.
Create a clean ‘greenfield’ CLM Shared Service and start to deliver benefits
2. Deliver Results:
Focus on transformational capabilities applied with real practical understanding of what good looks like, reset behaviours and ensure accountability for getting there.
Implement robust Portfolio Management of both in-flight and planned initiatives aligned with benefits tracking coupled to your economic framework.
Limit initial technology investment required and associated dependencies by converging on ‘best of breed’ existing platforms where they exist.
3. Manage Change:
Engage the organisation and stakeholders across the firm to win ‘hearts and minds’, reinforce points of connection with complimentary initiatives and inspire new standards of performance.
Shift to more agile ways of working and start to deliver through a containerised approach that avoids contamination from BAU and creates a culture of regular delivery of benefits.
Establish a Results Delivery culture across an accelerated period that aligns your leadership team.