Sanctions, Embargo, Suspicious transactions, PPE... How to ensure the success of an AML/CFT project?

For a few months now, not a day goes by without hearing the words sanctions, embargo, seizure of assets. Faced with an increase in alerts generated by surveillance tools and regulatory pressure, how can the success of an AML/CFT compliance project or clearance of a stock of alerts be ensured?

European regulators and governments are increasing the pressure on regulated companies, which must, on the one hand, manage the increase in alerts generated by surveillance tools, and, on the other hand, review and update their AML/CFT control process. They are confronted with stocks that must be cleared quickly to ensure (and reassure the regulator) that their customers are not registered on sanctions lists or do not engage in transactions that represent violations of the compliance rules in place. These operations are complex and often involve more investigation than simple control.

More than a simple verification – mobilized teams are required to contact customers, gather evidence, compile a complete investigation file, draft, and if necessary, pre-declarations of suspicions to FIUs (Financial Intelligence Units) and, finally, carry out precise reporting to the services concerned. These projects require an established – team of dedicated experts to manage the stock of alerts in the allotted time.

Although outsourcing the processing of AML/CFT alerts by an experienced player is one of the solutions recommended to meet these challenges, it is not that simple. Webhelp has extensive experience in outsourcing these high added-value projects, and has for many years developed strong convictions in key success factors.

Nicolas Dambrine, Deputy General Manager of Webhelp KYC Services, reveals the 5 key factors for the success of an alert eradication project:

1 – Immersion – a prerequisite for getting the project off to a good start

First, let’s look at the start-up phase. This is where it all comes together! The most crucial element of this phase is commitment: commitment of the service provider with the client, but also the commitment of the client with the service provider. It is essential to go to the customer, become familiar with their internal rules, absorb their knowledge and finally, validate with them the procedures to be carried out. Similarly, it is important that the client pays a visit to the provider; to plan and meet the operational teams, but also to pass on their knowledge and objectives on the project directly.

2 – Good indicators – for fine management

In parallel with this phase, it is vital to lay the foundations for reporting from the outset, taking into account the objectives of the project – productivity, quality, budget, compliance – or all four! Each of these objectives must be measured by precise indicators and managed – from the start of the project. This will make it possible to immediately examine the indicators and validate the theories made during the development phase. Moreover, in case of large volumes, having a powerful and well-configured reporting tool is not an option!

3 – The management team – true conductor of the project

The management team is a key factor on two levels. Firstly, the project manager who will be the link between the customer and the production teams. They must be senior enough, dedicated to the project and have a thorough knowledge of regulatory topics. Secondly, the production team leaders. They are the operational relay of the project manager and are responsible for motivating the advisors – who process the alerts and ensure a first level of control. It’s the famous random picking of processed files, which, thanks to the methodical application of a rigorous quality grid, should make it possible to detect any errors that may have been made. Generally, we recommend a ratio of 20% management in the start-up phase, and gradually decrease to 10% at the end of the project.

4 – Motivation – to ensure the success of the project

The project is launched, the management team is in place, the indicators and objectives have been defined – now it’s time to manage production! The first point that contributes to the success of the operation is to make sense of it. This may be true for all projects, but it is even more significant in the case of AML/CFT.
This starts with initial training and ongoing coaching, but motivation is also an important part of the success of the project. In fact, we found on a recent project that incentives had nearly doubled productivity within weeks! This was following a drop in the team’s motivation after a few months of operation, and indicators that tended towards red, we had to react. We decided to set up a challenge with big rewards – meeting and exceeding objectives would earn employees significant prizes. We saw an increase in productivity almost immediately, and the atmosphere of the production platform changed dramatically!

5 – Flexibility and adaptation – to achieve objectives

This brings us to being flexible which is essential and must be applied throughout the project. Here again, past experience shows us that constant questioning, adapting to the results obtained from week to week, as well as to external elements, are all key factors for success.
Test, measure the impact, implement, test again, modify. We are convinced that the processes must be regularly reviewed, challenged and improved in order to always be in line with the customer’s objectives. It’s a good practice that should be applied more widely.

Alert processing projects are complex but also energy-consuming, both in terms of time and in terms of human and technical resources. By deploying a team of experts with proven know-how and entirely dedicated to the client’s project, outsourcing makes it possible to meet the challenges posed by AML/CFT procedures within tight deadlines. Commitment, management, supervision, motivation, flexibility, and more importantly, people, are the guarantors of the success of an AML/CFT alert processing project.

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Could a proper KYC strategy have prevented ‘The Tinder Swindler’?

‘The Tinder Swindler’, true crime documentary recently released on Netflix which highlights the rising importance of identity verification, and on a broader level, fraud prevention. Could a KYC procedure avoid this kind of situation? We have asked Guillaume Casterman, Director International Projects & Knowledge at Webhelp KYC Services for their take on it.

First, let’s start with a brief reminder on KYC (Know Your Customer). These processes are intended to validate individual user identity information through data collection and analysis. They are a regulatory requirement for many businesses, mostly in the financial and regulated sectors to tackle money laundering and fraud operations. KYC procedures are applied to a broader spectrum of businesses such as car rental, crypto transactions, online registries and many more, so why not dating apps? The recent Netflix documentary, ‘The Tinder Swindler’, showcases how easy it is for someone to fake their identity online, to manipulate and catfish innocent people. Shimon Hayut, an Israeli fraudster and convicted criminal, pretends to be a billionaire businessman named Simon Leviev. Through this fake identity, he seduces vulnerable women via dating apps and convinces them he is in danger and needs large amounts of money.

Could a KYC strategy have prevented ‘The Tinder Swindler’ from scamming innocent women worldwide? Well, it could have made it harder at least.

How? The first thing to consider is that the various loans and credit cards were not in his name, and have not been contracted through identity theft. This makes it hard to prevent. But then there are two types of money lending: direct from his victims’ savings, and through loans and credit cards that his victims contract in their name. What could have raised the alarms? Opening a large number of relatively small credits through different banks should be limited by a credit-check before lending the money, and not only a revenue check. This would limit the amount that can be swindled. Then there is the credit card. When the credit card that he is using gets maxed out, which happens fairly quickly and frequently, the maximum amount available is raised by sending a fake payslip to justify that the account owner has enough money. This is where a good KYC onboarding could have helped. If the proof of revenue had been cross-checked (tax receipt checked through the official website, for instance), the newly provided payslip with an absurdly high amount, compared to what was registered during the onboarding should have raised a red flag. It is then possible to ask for more documents, to check directly with the company if this employee exists, even to cross check the employer against a database of similar alerts raised by other banks in different countries. Bear with me, this is not an easy check. But it can be possible when externalizing the KYC procedure to a global expert who can use their own fraud database, on top of external fraud listing sources. With this additional internal check, it is possible to identify when a payslip has been used in multiple similar cases, and when some of them have led to fraud sanctions. This could have helped limit the amount that the victim was able to raise, and make it harder for the swindler to scam those women.

Without a solid identity authentication procedure, users are left vulnerable to potential fraudsters and malicious actors.

In August 2021, Tinder announced that users will be able to verify their ID on the app in the ‘coming quarters’, in addition to the existing photo verification feature. At first it will be on a voluntary basis. ID verification will also be used to cross-reference data such as the sex offender registry in regions where that information is available. Although this investment in security features is promising, Tinder doesn’t say if this will ever become an obligation for its new user to verify their ID. The other question left is, what about the 75 million existing active users?

To be prevented, elaborated fraud requires elaborated checks. Internal resources and tools are usually not enough to prevent fraud, which is why calling on a global KYC partner with specific expertise and know-how can be the right solution.

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Know Your Customer

Three questions on... Know Your Customer

Jonathan Cowey, Webhelp UK’s Business Director for Regulated Services, talks us through the importance of Know Your Customer in 2022


Can you introduce yourself?

My name’s Jonathan Cowey, Business Director for Regulated Services here at Webhelp. I’ve spent the last few years really helping organizations transform their operations, particularly in the regulated space.


Why is Know Your Customer important right now?

KYC always has and will be important, but as the world becomes even more complex, whether that be data availability and integration, new regulatory pressures or, for example, the year on year increase in sanctioned individuals, Politically Exposed Persons (PEPs) and fraud that we see, it has never been more important to get this right.

And I think what also puts this at the forefront of many conversations and discussions that we’re having is the amount of recent failings that we’ve seen. The regulators have issued fines in the hundreds of millions of pounds in the last twelve months, because organizations simply didn’t get this right. And the subsequent cost to remediate and clean all of that up are also massively impacting organizations’ balance sheets.


What should firms be thinking about next when it comes to Know Your Customer?

The real key here, in my view, is striking the right balance between technology and humans. I don’t see any one solution where everything is automated, because of the complexity and the risks that are involved.

But we also know that we can’t solely rely on people. And so, bringing together a strategy that augments these two elements wrapped up in a KYC and regulatory expertise, in my view, will be key to getting this right in 2022.

Now, in order to do that, partnerships with organizations who do this really well and at scale will be actually a real critical consideration. And I think exploring that will really help organizations for new complexities that will no doubt arise this year. But I also think this will help get ready for new regulatory expectations.

Continuous KYC is a good example of that, which we know many of our clients are grappling with today.


Jonathan Cowey is a Business Director with extensive experience delivering operational and customer journey transformation projects within the retail banking sector, including particular specialisms in leading transformations in fraud and anti-money laundering environments.  

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KYC: unlocking the Chinese puzzle to onboarding sellers on international marketplaces

The challenge is a familiar one: to build or develop your international marketplace, you must quickly take on tens of thousands of sellers from all countries, especially China. This involves setting up a KYC assessment process for these sellers that is effective and fully compliant. What’s the right solution? Setting up a digital platform allowing sellers’ files and their analysis in their original language to be collected, as explained by Alexandre Perrachon, Sales Director of Webhelp KYC Services.

Online sales have doubled over the past 4 years, reaching $4.5 billion in 2021. In 2022, this movement will continue and it is estimated that nearly a quarter of online purchases will be international. 2022 will therefore be marked by a large scale challenge: hypergrowth in international marketplaces. With this in mind, the topic of widespread onboarding of national and international sellers will become central.

As we will see, a well-managed KYC procedure makes it possible to meet two major challenges: guaranteeing regulatory compliance and offering sellers a simple and quick onboarding journey.

1 – Ensure compliance: comply with the regulations of the countries concerned, and adapt to their successive developments

When assessing sellers during onboarding, it must be possible to detect cases of fraud but also to ensure compliance with current international regulations. This presents 3 difficulties:

  • these sellers must meet numerous criteria including some that are particularly strict (declaration of beneficial owners, non-registration on sanctions lists, etc.),
  • national and international regulations are constantly changing, moving towards stronger controls, which require a structure for legal monitoring at international level,
  • the types of proof of identity (legal entities and natural persons), the company registers vary from country to country and sometimes even from region to region within the same country, as is the case in China for example. Hence the need to have a thorough knowledge of current practices, and the ability to analyse documents in their original language without having to call upon certified translators.

In this context, more and more marketplaces are turning to specialists able to digitalise this process, such as Webhelp KYC Services, which provides:

  • a wide geographical presence to be as close as possible to the sellers (Europe, Asia, Africa, the Americas),
  • far-reaching expertise in languages to analyse the files and guide the sellers on their onboarding journeys (experts in 50 languages),
  • international, national and regional regulatory expertise,
  •  extensive experience in the fight against fraud (making it possible to build document fraud databases that can be shared between marketplaces)

2 – Offer the best experience to sellers, turning it into a competitive asset

To attract as many sellers as possible, marketplaces need to provide a seamless and fully integrated user experience. This usually involves digitalising the collection of documentation and information that make up the sellers’ files.
To maximise sellers conversion rates, marketplaces must also be able to analyse files efficiently at times absorbing large increases in volumes from one month to the next (especially just before “peak seasons” such as “Black Friday” or the festive season).

In this quest for flexibility and operational efficiency, again, marketplaces or their payment service providers (PSPs) are increasingly turning to specialists carrying out the onboarding of sellers by mixing the best in automation technologies with the work of expert analysts, to guide sellers throughout their journey.

Again, outsourcing has significant advantages:

  • personnel numbers in teams can be adjusted as you go, depending on the need (annual peaks or troughs in activity, seasonal peaks, etc.),
  • large scale deployment is possible, nationally or internationally, without HR being faced with huge recruitment operations that are hard to handle,
  • in-house teams can become loyal and upgrade their skills because they focus on tasks with high added value.

These sellers must be onboarded en masse and as quickly as possible, usually within 24 or 48 hours.

Outsourcing of onboarding: a good solution, with some conditions…

In international markets, outsourcing seller onboarding is the current trend. Awareness will become widespread in 2022: leading brands will prefer to focus on their core business – a perfect customer experience – and delegate tasks such as onboarding national or international sellers to specialists.

Outsourcing makes it possible to focus on such priorities, but with a word of warning: almost all KYC service providers rely on a technological solution, but they do not have sufficient, qualified personnel. However, an experienced team must be able to take over as soon as technology hits a problem (illegible, incomplete, outdated or fake document, etc.). This should be done within 24 hours in order to maximise the number of sellers onboarded. This sometimes involves contacting them, in their own language.

For example, to process onboarding requests from Chinese sellers, Webhelp KYC Services relies on its local teams in the APAC region (Asia Pacific), specialising in KYC operations and fluent in Mandarin Chinese. The stakes are high as China is now the largest e-commerce market with $672 billion generated by online sales in 2020.
For large Chinese – or American – marketplaces that want to develop in Europe by accelerating the onboarding of local sellers, it now seems essential to also rely on KYC management platforms that master the specific characteristics of each country (different regulations, multiple languages, cultural approaches and different uses…).

In conclusion, all marketplaces that have growth ambitions, or even hypergrowth ambitions, face a “puzzle” when it comes to onboarding sellers from all over the world: How to attract them? How to collect their onboarding requirements? How to maximise their conversion rate by providing the best user experience? How to ensure compliance with each country’s regulations?
To solve this “puzzle”, it would appear that using a specialised platform that is multilingual and combines technology and human capability is necessary. This is the choice that key leaders are making today to support this growth.

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KYC remediation

The 4 key indicators of a successful KYC remediation campaign

KYC remediation

Knowing Your Customer (KYC) is at the heart of the challenges faced by regulated companies and financial institutions. In fact, they are subject to the European legislation to combat money laundering and the financing of terrorism (AML/CFT) and are obliged to carry out KYC checks. This involves collecting and checking information and associated supporting documents from the beginning of the relationship (identity, domicile, activity, etc.). These KYC operations also occur throughout the commercial relationship in the form of periodic reviews.

In the event of a breach discovered during an audit by a regulator, such as the ACPR (the French Prudential Supervisory Authority), companies face serious consequences such as criminal sanctions. They also risk damaging their brand image in the event of indirect involvement with a case of money laundering or fraud. Some organizations are also required to launch extensive KYC remediation campaigns aimed at making a substantial stock of existing customer records compliant, often before an imminent deadline. In such cases customers are asked and invited to update their file as soon as possible. These operations require special attention in order to maximise the remediation rate of these customers, while managing the associated investments and customer satisfaction.

In order to optimise the performance of a KYC remediation campaign, Guillaume Bru, Project Director at Webhelp KYC Services, recommends paying particular attention to 4 key indicators:

1/ After taking an inventory of the customers targeted by the campaign, ensure a maximum deliverability rate of the invitations in order to reach the largest number of customers.

The essential point is identifying which contact channels to prioritise according to the type of customer (email, post, SMS, telephone, etc.) and confirming having the means of contact used by each customer (email address, telephone numbers, postal address, secure messaging in the customer’s account, etc.). By having the option of using a variety of channels, you will increase your chances of reaching the customer with one of these methods. On the other hand, in order to control costs, prioritise mail only when necessary – for example, to customers less comfortable with digital channels or in the case of a final reminder.

2/ Once the customer is aware of the update request, the second indicator to be optimised is the take-up rate corresponding to the customers’ consent to the update of their file.

In fact, some customers complain about the constraints associated with these administrative formalities. Above all, it is necessary to prepare and use reasoned and personalised arguments, given by expert, trained members of staff. We have seen that 95% of customers agree to carry out the remediation following a well-reasoned call with one of our advisors. Also, rely on the official communication channels used by your company in its relationship with your customers (corporate website, customer support, etc.) in order to rule out any suspicion of phishing, for example.

3/ Customers must then be able to take action and provide whatever is required in order to obtain a maximum collection rate.

To do so, make it easier for them to cooperate and favour user-friendly digital channels, while leaving the door open to traditional channels such as post. You can also directly ask the customer what their preferred method is. Anticipate their questions and answer them if necessary. Offering support through a hotline or a chatbot is a good way to overcome any final obstacles they may face. Finally, in the event of a lack of response, send reminders with prompts, progressively and sufficiently spaced out to both control costs and preserve the customer relationship.

4/ Finally, the last key indicator to optimise is the compliance rate of the files collected.

Some files may be rejected due to incompleteness, illegible supporting documents or still being out of date. Raising the customer’s awareness beforehand of the required quality of the documents to be provided will help to avoid many rejections. Also, it is important to be pragmatic andadapt the level of the requests based on the assessed degree of AML/CFT risk. Analysing pre-existing information will also potentially reduce the number of items to be collected. Finally, in the event of a non-compliant file being received, set up a specific follow-up process to make the file compliant.

Define and prepare the campaign in advance by implementing a process that combines technology for automated tasks and people for high-value tasks. Throughout the remediation campaign, set goals, particularly for remediation rates that you will manage each week by optimizing these 4 key indicators. It is also wise to demonstrate flexibility by testing and adapting each element of the process in order to continuously improve results. This is the key to a successful KYC remediation campaign.

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KYC remediation

[Banking, Insurance, FinTech] KYC Remediation: how to outsource without sacrificing customer experience

KYC remediation

The purpose of KYC remediation procedures, which regulated establishments may be required to carry out, is to upgrade client data and to ensure that it is compliant. Faced with large amounts of data to process under tight deadlines, many companies choose outsourcing. But you need to be careful. KYC operations are delicate. They can have an unpleasant impact on end customers and thereby lead to the closure of customers’ accounts! However, as Nicolas Dambrine, Managing Director of Webhelp KYC Services explains, they are also an opportunity to get to know your customers better and even to boost their level of satisfaction.

KYC remediation refers to compliance operations that concern existing clients, in the context of KYC (Know Your Customer) regulations. It involves collecting, updating and checking customer data and the supporting documents, in particular, for identity, address and activity, as well as for tax. As a rule, with a regulated company (such as a bank, an insurance company, a payment institution or with FinTech), it follows:

  • Pressure from the Regulator (the Prudential Supervision Resolution Authority, or ACPR in France), requiring a particular group of customers to be brought into compliance, sometimes with the threat of a fine
  • The entry into force of new regulations which, to be complied with, require the database of existing customers to be updated
  • Receipt of a banking licence or the acquisition of a banking institution, meaning that the database of existing customers needs to be updated so as to ensure uniform adherence to regulatory procedures

For many financial institutions, these remediation obligations pose several challenges: how can you implement a large number of operations in a short time and in a reliable and traceable way? How can you maximise the data collection rate so as to avoid closing the accounts of customers that did not respond? Finally, how can you minimise the impact on customer experience and avoid tarnishing the image of your brand?
After all, we should remember that a remediation initiative is rarely a happy experience for the end customers. It may appear intrusive or be viewed as a form of phishing that could compromise the confidentiality of their personal data.

While outsourcing KYC remediation is a very suitable solution to address these issues, it is not something you can improvise! For Nicolas Dambrine, there are a few golden rules to follow when it comes to outsourcing a KYC remediation initiative:

  • Work out a methodology with accurate planning and topic-focused workshops, so you can prepare each stage of the project in advance and prevent technical, operational or human errors before the project gets under way.
  • Get the help of a project team with both the right size and experience over the whole course of the initiative. It is easy to underestimate the workload, so it is better to invest a little more at the outset to ensure the project is well managed.
  • Prioritise operational efficiency and process optimisation with an end-to-end solution combining technological and human elements. The truth is that although technology is transforming and accelerating the process of remote identification, no platform can claim to automate 100% of operations. Some complex procedures will require the involvement of teams of expert operators focused on value-added tasks and interaction with customers.
  • Set up a dedicated telephone helpline right at the start of the initiative, allowing the end customers to ask questions and to check if the operation is legitimate, or to get help with completing the remediation process. We found out that 95% per cent of customers who contact this hotline agree to carry out the remediation, which is thanks to the quality of the advice from our expert agents. So for your initiative, this is a great way to increase the rate of compliance! This communication channel is also an opportunity to improve your customer relations and to strengthen the bond with your end customer: by getting updates on their situation or on their contact details, or hearing them express their needs and their problems …
  • Establish accurate reporting and metrics beforehand, as they are essential for managing the project and achieving your objectives. They will enable you to monitor its progress and take decisions at the right time in the event of a change of course.

These five factors, if they are properly taken into account, are the keys to the success of an outsourced KYC remediation initiative.

When you make customer relations central to the whole operation, KYC remediation campaigns can give you an opportunity to improve the relationship with the end customer and to boost customer loyalty over the long-term, thanks to reassuring advice provided by experts.

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