KYC remediation and refresh
Client-first is at the heart of everything that JDX does.
We shape our consulting capabilities, services, and experiences around our clients, working with them, and our partners, to design and deliver solutions with outcomes that target our clients’ pain points, unmet needs and real business problems. We use our unique perspective to provide optionality in the client outcome, while unlocking value throughout the journey. Today’s JDX client story showcases one of our Client Lifecycle projects.
Our client, a Tier 1 European global investment bank, required a KYC Periodic Review and Remediation programme in September 2018. The project targeted over 12,000 client files across 7 different jurisdictions over a 1.5 year period. The project scope included:
- A full suite of client entity types:
- private entities
- listed and regulated clients
- Both complex and simple entity structures
- Low and medium risk files
- Ability to identify high risk client triggers
JDX deployed a ringfenced team of 40+ staff including 1 senior project manager, 1 assistant manager, 4 sub team leads, 25 KYC analysts, 10 QCs and 2 MI personnel. All analysts completed JDX’s accredited KYC training programme and client confidentiality training prior to deployment, as well as training on the client’s own policies and procedures. Training covered details on KYC policies and procedures, client entity types requirements, UBO determination, identification and verification documentation requirements, Screening procedures.
JDX prioritised and allocated work for each of the JDX analysts in line with the direction and high-level targets set by the stakeholder. The team provided weekly MI and KPIs to the stakeholders to track progress and performance. Allocation of files were grouped by parent organisations where possible to avoid duplication of outreach for outstanding KYC information.
The JDX Team performed:
- Public searches and initial due diligence
- Client/sales outreach
- Ownership structure and UBO determination
- Screening for Adverse Media,
- Sanctions and Embargos
- AFC escalation
- Co-ordinated Front Office approvals
- Quality Control
- Co-ordination of offboarding for non-compliant accounts
- Project management
- Governance and oversight
- Including MI production and weekly status reporting
Outcomes / Measurable impact
The initial target of 2000 reviews for the 2019 year-end deadline was met with a small residual number of entities being carried forward into the 2020 population due to lack of responses from sales/clients.
10,000 files were allocated which were completed on track within the regulatory deadlines. JDX supported the client to successfully meet regulatory deadlines as well as supported them to complete a relocation strategy for their periodic review teams without impacting targets.