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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