Project Objectives
Brighter Consultancy was appointed to:
- Develop and implement a unified AML client screening system to replace outdated and inadequate solutions.
- Recruit and mobilise specialist AML resources across Operations, Technology, Risk, and Process Management to drive the transformation.
- Ensure regulatory compliance by aligning the programme with audit findings and reporting requirements from key regulators.
- Manage vendor selection and system integration, including the replacement of existing providers and the decommissioning of legacy systems.
- Enhance process governance and escalation models, ensuring a more structured and centralised AML approach.
Our Solution
Brighter Consultancy established and executed a large-scale programme following these key principles:
Customer-Focused Approach
Created a collaborative global function that prioritised customer and business value while ensuring regulatory compliance.
Regulatory Audit Alignment
Designed solutions in direct response to audit findings, incorporating regulator recommendations into system design and governance frameworks.
Improved AML Servicing & Onboarding
Ensured that the new system and processes enhanced AML screening, benefiting both the bank and its customers.
Process Management & Risk Governance
Developed new 1LOD, 2LOD, and 3LOD frameworks aligned to the capabilities of the new system and best-practice methodologies.
Vendor Management Overhaul
Created new service agreements and SLAs with the selected third-party provider, replacing outdated agreements and improving system performance and incident resolution.
Technology & Automation Integration
Worked closely with internal and external IT SME support functions to implement a fit-for-purpose AML solution that met operational and compliance requirements.
The Difference We Made
- Designed and implemented a global AML Change Programme, addressing key regulatory gaps and ensuring compliance with FCA and CBI requirements.
- Established a robust PMO function, capturing reporting, tracking progress, and ensuring alignment with C-suite and regulatory reporting obligations.
- Created a centralised escalation model, replacing fragmented regional models with a single-country approach, improving consistency and expertise in regulatory escalations.
- Optimised operational efficiency, delivering 112 FTE savings, equating to £3.92m in annual cost reductions, by implementing a Target Operating Model (TOM).
- Ensured alignment with ongoing FCA audit requirements, working alongside the business to implement outstanding regulatory programme commitments.
- Developed and delivered comprehensive training and procedural materials for 250+ staff across four global locations, with materials reviewed and approved by regulators to demonstrate compliance with audit recommendations.
- Redesigned the 3LOD escalation process, enabling faster and more structured regulatory reporting, significantly reducing the risk of further regulatory intervention.
Outcomes
- A unified AML client screening system was successfully implemented across global operations, replacing multiple legacy systems.
- Regulatory compliance was fully achieved, with positive feedback from the FCA and CBI on the bank’s remediation efforts.
- Operational efficiency and cost savings were realised through FTE reductions and streamlined escalation processes.
- Standardised governance and risk management practices improved consistency, audit readiness, and organisational alignment.
Brighter Consultancy’s strategic leadership not only resolved critical regulatory challenges but also delivered a sustainable AML framework that enhanced compliance, efficiency, and long-term operational resilience.
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