High Risk Customer Review To Meet Regulatory Requirements

Client: Top 25 Global Bank

The Challenge:

The Investment Division of this global financial institution was required by regulators to improve the Enhanced Due Diligence (EDD) reviews of high-risk customers and clear the backlog of required assessments triggered by previous changes to their rating approach. The division needed to demonstrate all processes were consistent, sustainable, and repeatable while maintaining capability to conduct them as Business-as-Usual activities. Our client lacked the expertise and bandwidth to comply through internal efforts.

The Solution:

Eliassen Group deployed a team of experts to apply process stabilization and overall sustainability to deplete the backlog of reviews, train and coach team members, execute quality assurance of risk assessments, and make decisions to retain or exit customers. Our team performed gap analysis identifying impacted populations, requirements to clear backlogs, and concerns raised by risk leadership, Internal Audit, and regulatory examiners. The analysts deployed multi-phased production model, enhanced workflows and procedures, including the completion of multiple quarterly Enhanced Due Diligence reviews. Our experts developed a roadmap for sustainability that included ongoing communication of priorities, senior leader engagement, reporting and implementation of a continuous improvement approach. Further, our specialists drafted, validated, and deployed desktop procedures enabling consistency across reviews. Finally, we enhanced overall program governance including high-risk customer reporting and sustainable resourcing models.