Our client, a renowned Asian bank with a full banking license and a well-established business model in Germany/EU, was confronted with challenges in the area of money laundering following a special audit by BaFin. These related in particular to risk analysis, KYC (Know Your Customer) and transaction monitoring, including correspondent banking.
The client placed its trust in DIGITAL IMPACTS.
At the start of the project, we faced a number of challenges:
- The client and especially the parent company in Asia were initially skeptical of our consulting services, as they had only worked with larger, better-known consulting companies in the past.
- The time to report to BaFin was short, as the bank had already been operating independently for six months.
- BaFin’s findings were comprehensive and complex.
Within the scheduled 3.5 months, we were able to successfully close most of the gaps and initiate the necessary IT implementations for the remaining part:
- Together with the money laundering officer, we defined clear objectives and the necessary activities for each finding.
- We drew up a detailed project plan and transparent reporting to bring all stakeholders on board and overcome the initial skepticism.
- In a kick-off meeting, we presented our approach, the required contributions from the bank and the consequences. We obtained the agreement of the management and confirmed our commitment.
With a team of three experts, we were able to successfully complete the project:
- We developed a new methodology for the risk analysis that took into account BaFin’s findings.
- A comprehensive risk analysis was carried out to identify further opportunities for improvement and eliminate the gaps identified.
- Based on the findings, improved controls for KYC and transaction monitoring were defined and implemented.
- New monitoring scenarios were selected, the threshold values of the existing scenarios were adjusted and handed over to IT for implementation.
The project was successfully completed with a final presentation for internal and external purposes, including submission to BaFin.
