As the programme required a global AML initiative across all business units, P2 Consulting mobilised a team of analysts trained in core banking AML and sanctions regulatory processes. An innovative and agile approach was taken to organise the team structures, with teams representing different geographical regions. All business units were assessed to ensure they had the right systems, policies, procedures and processes in place and were able to run periodic reviews and audits to ensure compliance with AML and sanctions legislation. This discovery and identification work needed to be completed within a very tight deadline to provide timely reports for banking regulators.
Flexibility was key, as the responses from the different business units were not submitted in a uniform way and resource needed to be moved between the different teams in order to cope with the fluctuating workload and meet specific priorities at specific times. We also provided a PMO service to manage the workflow and a Kanban approach was adopted in order to track each individual business unit through potentially multiple iterations of review and response.
As the evidence provided by the business units varied in format and content, P2 Consulting needed to develop an assessment process that used both automated and manual checks to process the large volume of data.
We were able to highlight areas of inconsistency between responses and evidence, including areas where year on year variation was unacceptable. These findings were then presented back to the individual business units. The responses back from the business units then had to be carefully analysed to ensure that each query could be closed.