KYC remediation project: focus on Mid Term and Long Term wins rather than pure backlog remediation
Business Project Approach
Step 1: Gap analysis against regulatory requirements & best practice benchmark
Top-down approach: End-to-end review of Framework, policies, procedures and tools vs. current regulations.
• Bottom-up approach: Review of KYC files in each jurisdiction.
Step 2: Remediation
Gaps in the bank’s actual practice and bank’s theoretical policy are remediated according to check lists compliant with regulatory requirements.
Step 3: Process optimization & Change management
Process standardization and change management towards Client Management and RMs and implementation of tactical tools to better monitor the quality of KYC.