Insight
Financial Crime Remediation Programmes can succeed. They can be delivered on time and to budget. We've put together a guide with instant access to our top tips and strategies to help you through the process.
1. Programme Assessment
2. Governance
3. Control Environment
4. Management Information (MI)
5. SLAs
and a few other things ...
Clear line of sight over volumes and complexity
Map out end-to-end processes & agree SLAs. Seek buy-in and unity of vision
Review and understand relevant frameworks [policy/process desktop procedures] make recommendations for improvement and optimisation
Build a training plan to provide rapid upskill and knowledge transition
Road map to ensure team are fully operational by agreed period
Agree run rates: productivity and quality (RFT)
Define rhythm of interaction with team and key stakeholders
introduce regular and structured status briefings to track milestones and deliverables
Establish an effective controls environment and escalation channels to ensure risks and issues are mitigated
to capture project status and progress and delivery against KPIs
Build in practical measures to ensure transparency of operation (plan for regular engagement, pledging mechanism, hotlists, interactive sessions).
Ensure the appropriate level of skill, expertise, and capacity to manage demand
Appropriate reporting should be in place to monitor and manage project deliverables and SLAs. Establish strong governance from the outset to oversee performance and facilitate rapid decision-making and issue resolution.
Don't forget: Remediation / backlog clearance projects succeed primarily because of early engagement of key stakeholders, the iterative development of remediation standards and the continuous confirmation of risk issues, risk appetite and ownership of files moving to BAU at file sign-off.
A successful project needs an effective controls structure and intense rigour to ensure risks and issues are mitigated. It’s important to thoroughly assess your control environment.
Lets check...
Measure and communicate progress and identify common problem areas that may yield opportunities for continuous improvement. By tracking these criteria against predefined targets and tolerances, an understanding of how a function is performing can be made, as well as identifying any areas that require attention.
Events: tracking of events (SLAs / Quality)
People: individual and/or team performance and/or measuring communication of issues requiring management attention
Systems: efficiency of software and tracking of "downtime" (is the KYC system actually fit-for-purpose? How is downtime affecting performance?)
Processes: identifying bottlenecks, touchpoints or aging. Escalating risk & policy conflicts
Productivity: assessment on team productivity and a measure of how this tracks to plan
The components of the MI should be mutually agreed by all parties covering core presentable data in respect of KPI's and SLA's against each workstream.
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Key project items should be included within a RAID Log, to ensure risks, actions, issues and decisions have been fully recorded and reported.
Answering these questions will ensure an organisation doesn’t fall into a backlog/ remediation cycle in the future. It is vital to identify opportunity for process enhancements and efficiencies along the way and feed this into BAU.
As a remediation programme progresses, there should be regular opportunities to review and refine the SLAs based on actual performance data, changing business needs, or external factors. This ensures that both parties remain aligned and that service delivery continuously improves.
We’ve highlighted some areas of especial focus you might wish to consider:
Clear, documented workflows must be
established and shared with all functions. Production teams should be working with a unified understanding of the procedures, escalation paths, and decision-making criteria. This ensures a level playing field where all parties have a common operational framework.
A regular governance structure (e.g., weekly or even daily review meetings) should be in place to assess the effectiveness of the processes, discuss potential bottlenecks, and ensure alignment across teams. Keep this process dynamic and responsive to operational needs.
Gathering feedback from analysts can provide invaluable insights into process inefficiencies or systemic issues. Regular feedback loops should be established (and maintained).
Analysts must have access to the right tools and technology to perform their tasks efficiently. We recommend that an initial technical assessment be performed to ensure compatibility and that analysts can work at optimal speed.
Both parties should have access to real-time performance data. This can be achieved through dashboards that monitor individual analyst performance, case progression, and overall SLA adherence. Transparency in this data will allow you to identify trends, inefficiencies, or areas for improvement.
Analysts need to have clear, open communication channels with relevant stakeholders. This allows production teams to stay in sync and respond to challenges in real time, minimising disruptions. It's all about close collaboration!
If cases require escalation (e.g., complex KYC/AML checks), there must be clear and timely escalation path to compliance, or relevant departments. This prevents any bottlenecks and ensures analysts can continue to work efficiently.
In the event that SLA targets are missed, there should be a structured process for dispute resolution. This ensures that any issues are addressed fairly and promptly. The focus should not be on protracted and enduring back/ forth discussion , ensure key stakeholders are in position, reach common ground and take action.
We recommend establishing a flexible resource allocation model. As the complexity or volume of work fluctuates, there should be provisions to scale resources (either up or down) to ensure that SLAs are consistently met without overcommitting to a rigid resource plan. Are you comfortable that your capacity plans are based on reasonable assumptions? Are BAU functions well balanced and staffed to support increased operational demand?
To avoid variance in performance, all analysts must undergo the same level of training and operate under uniform principles. Any gaps in understanding should be addressed upfront to ensure analysts can work independently and hit the agreed targets.
As the programme progresses, there should be regular opportunities to review and refine the SLAs based on actual performance data, changing business needs, or external factors. This ensures that both parties remain aligned and that service delivery continuously improves.
Gathering feedback from production teams can provide invaluable insights into process inefficiencies or systemic issues. Regular feedback loops should be established to quickly address any operational challenges and maintain high productivity levels
In our view engaging a dynamic and multi-skilled Pod structure works well in time sensitive/ volume heavy pieces of work. It keeps the operation transparent and fully functional, with all moving parts
and MI filtered through the management structure up to the Programme Director.
Let's get very clear on scope. Have you identified specific issues that need to be addressed ensuring that efforts are concentrated on the most critical problems? A well-defined scope outlining purpose, deliverables and success criteria ,including development of metrics, benchmarks and expectations is essential.
How are you prioritising your efforts?
Prioritisation ensures that resources (time, money, personnel) are directed towards the most critical tasks maximising productivity and maintaining customer relationships.
A sensible approach is to prioritise based on the percentage of expected customer outreach. This is to ensure maximum available time for customers to respond to outreach requests and allows the team to make the outreach and move quickly and efficiency to the next case without delay. It is also useful to have a team dedicated to High-Risk customers and prioritise this tranche for completion as they can pose the greatest regulatory risk to the organisation. They are also more complex in nature so it's important to get a good head start and make effective use of any down time whilst waiting for return documentation.
Toptip: Ensure there is a well thought through notice to close process in place and clearly defined consequences (backed by senior management) for non-return of information.
Chasing customer’s aimlessly requesting the same information in a similar tone each week is un-productive.
QC would usually commence at 100% sampling on a small selection of targeted cases. This will immediately reduce once analysts routinely achieve a high percentage of right first time and become accredited.
This helps to balance quality with pace of execution in safe knowledge quality has been tested and assured.
Segment population and identify characteristics with most cause for concern.
Toptip: Assign cases tactically amongst the team so you can group cases where possible, achieve quick wins and avoid unnecessary customer disruption.
A unified visionensures vendor team and client team understand the objectives and have a shared commitment to delivery. It sounds nice on paper, but bringing this to life in a live multi- person operation is crucial. When the team shares a common vision it can more easily adapt to change – and we know that remediation programs can often change course! Active engagement encourages dialogue allowing teams to share insight that lead to better decision making.
The vendor team should work as an extension of the client’s team with the principe aim of building relationships and trust from the outset. A ‘’them / us’’ approach never works. Are there forums in place to transparently address issues and also celebrate collective efforts of the wider teams?
Whether you are dealing with a large-scale transformation or a tactical piece of top-up remediation, co-ordinating efforts will reduce the likelihood of errors and oversight. SO, is your governance structure effective, is ownership and accountability clearly defined?
This is all about being alive and open to positive change. If a process needs enhancing, of a policy needs updating, it is always worth assessing this in the context of what is best for the business. Assess the benefit, assess the impact and implement the change.
Ensure a clear plan during ramp up. This phase is not just for a vendor team or new joiners to ‘’read a policy and take notes’’.
Ramp up will provide practical working knowledge and key insight into lead times and key dependencies for case completions.
Toptip: Work on pilot cases as soon as possible;
- Test the process
- Assess escalation channels
- Review SLAs
- Identify blockers
- Conduct a time in motion study to assess case completion times.
Present a check point view of progress by end of month 1. What has gone well, what needs to change, and how can you implement this change with immediate affect?
We love what we do - we help customers who are facing regulatory intervention, we solve complex breaches, we bolster operational teams during growth periods, and provide managed services in all areas AML, Financial Crime, Fraud , Sanctions, you name it!
If it’s a remediation you need to kick start ( or rescue!) a backlog you need clearing, classic assurance and advisory , or external support to deliver on your transformation agenda, reach out to our friendly team today.
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