Temaswiss' Integrated Key Risk Controls (IKRC) best-practice design for Commercial Banking KYC and AML Transactions Monitoring.
- Commoditised Consulting & FSI Advisory packages.
- Tailored to your data & process realities.
- Budget- & Time-bound.
1. January 2016
Lead consultant contact:
+65 8138 7340
coo@temaswiss.com
Integrated Key Risk Controls, Reporting & Automation
Sample(s) for this presentation:
CB-XBO.01 Commercial Banking KYC, Fraud Mitigation & AML Monitoring (incl. Sanctions)
2. Who We Are
DigiScape provides bespoke multi-level risk management solutions arm for the financial services industry. TEMASWISS is, since August 2015,
the bespoke consulting and training arm of DigiScape.
Temaswiss’ consulting, training and analytics arms is at its core, a think-tank of veteran bankers, risk managers and financial crime risk specialists
with a combined experience exceeding seventy years.
In its consulting value proposition, it focuses solely on expertise in Operational Risks, Regulatory Compliance, Sales Governance, AML & Transactions
Monitoring and Conduct Risks for Commercial and Private Banking.
Unparalleled point-in-time insights from C-level Legal, Compliance and Operational Risk banking industry practitioners, MAS Singapore and other
ASEAN & South Asian Regulators on: audit results, regulatory guidance, practical implementation challenges.
Each of our holistic engagements are led, throughout its life-cycle, by a senior consultant with detailed expertise and hands-on experience on
banking processes, regulatory requirements, industry best practices and pragmatic solutions for specifically the risks to be mitigated and processes
to be revamped.
Quality being foremost, we operate by engaging the regionally best-in-class expertise from a large pool of outreach specialist consultants and we
have no more than 3 major engagements underway at any given time.
Focus is upon process advisory and mapping between the strategic initiatives and comprehensive integrated risk-mitigation programmes of banks
and the service provision of solution providers.
As a sit-beside organization, we provide un-conflicted support to our financial services client to vet and to select controls automation, interface, data
tool and technology provider that best fulfills the requirements.
3. Unique Insights - Cumulative Learning To Your Benefit
Root cause analysis of fraud incident was incomplete and detection scenarios were not adapted accordingly.
AML and Fraud detections scenarios are standardized and not satisfactorily tweaked in variation to relevant banking segments,
products and geographic variations.
Excessive redundant data and alerts are being produced from the transactions monitoring systems due to inadequate fine-tuning
of alerts generated.
Relationship bankers and/or middle-office and/or transactions monitoring staff are inadequately trained on the latest trends.
The regulatory reporting does not capture the data for XX products and/or XX transactions that do not follow the usual channels.
Due to the grandfathering of pre-existing customer KYC data, the detection scenarios for AML/ fraud are no longer effective.
Due to process inadequacies the alerts were not timely escalated to AML/ Regulatory Compliance.
Although Politically Exposed Persons were detected in the ownership structure, the accounts were not subjected to Enhanced
Due-Diligence.
Range of Regulator’s Long-Form Audit & External Audit Issues Raised
4. Common Pitfalls (What Do We Help You Avoid)
Excessive
“False-Hits” due
to Inadequate
Rules Engine
Customisation
The bank data
realities do not
match tool
capabilities
Literal
‘reading’ of
Regulatory
expectations
without Risk
Mitigation
Focus
Cost & Effort
exceeds budget
and the Bank’s
risk appetite
“Off-the-Shelf”
solutions that are
NOT optimal
Inadequate 3P
(Process, People,
Procedures)
Parametrisation
Support
5. End-to-End Engagement and Beyond
Present-State
Evaluation &
Concurrence on
Risk Mitigations
Advisory &
Consultation on:
Gaps, Risks, Best-
practice controls,
Control functional
alignment and
process placement
Enhancements:
Immediate or Interim
Manual Controls,
Implementation of
controls, operating
manuals, Reporting,
Training & MI.
Strategic Engagement:
Controls SMARTS
assessment, automation
SWOT analysis, stake-
holders engagement,
project management
infrastructure, RFQ
Off-The-Shelf*:
Research and
proposition of
Best-suited
solution and
provider
White-Labelled*:
Alignment of
additional
requirements,
interface process
design
Greenfield
Development*:
Identification &
Evaluation of Data
sources & inter-
facing required,
Ops processes
End-to-End Programme
Management:
- Data current-state
Evaluation.
- Tool development
(only for greenfield)
- Project resources
- Vendor management
- Project Business Info
Security & Tech Info
Security competencies
- Dashboards, MI &
Stakeholders reporting
- operational process
alignment
- UAT design and
conduct
-assurance design
Fine Tuning:
- Multi-months
Helpdesk services
- UAT residual
remediation
- Source-code and
knowledge securing
-Audit preparedness
Training:
- Training material
- Primary Users
- Assurance Users
- MI & Dashboards
design & production
-Lag avoidance measures
Maintenance:
- System Patch Alerts
- Regulatory & Industry
Best Practices Advisory
- Periodic Enhancements
- Periodic Data quality
and effectiveness
assurance reviews
End-to-end
process audit
by us,
Controls
function
corroborative
engagement or
desktop
review. Or
combinations
thereof.
Holistic reporting
encompassing review of
established controls and
reliability of situational
and contextual risk
mitigants. Disclosure of
fragmented, missing or
ineffective controls,
regulatory point-in-time
expectations, peer audit
results, industry best
practices. Complete with
advisory on proposed
baseline controls.
Stakeholder engagement,
proposal, buy-in and
implementation of where
either existing controls
could be enhanced or
immediate/ interim
control placed at low
effort and costs to
materially mitigate risks
or audit adverse results.
Aligned to management
risk appetite and
acceptance.
ASSESSMENT LOW –HANGING FRUITS STRATEGY FORMULATION SUSTAINABLE DEVELOPMENTS
* Technology vendor proposal always at arms-length versus vendor.
! Express Compliance to
new entrant / new
jurisdiction / enhanced
regulations. e.g. MAS 626