Remediations are challenging, often pushing financial crime teams beyond their capacity and immediate capabilities. Many firms need additional resources, support and guidance throughout the process. And the same key questions are repeatedly asked.
To tackle this, grab a cuppa and let’s chat about all things remediation in this rapid fire Q&A. In five questions, James Nurse, Managing Director at FINTRAIL and Ian Christie, Senior Resourcing Consultant, answer your most pressing remediation queries.
Q1. What types of remediation programmes can FINTRAIL support?
At FINTRAIL we cover the full spectrum of remediation issues, whether that be issues with controls and associated enhancements, backlogs, or adapting requirements across BAU processes and first line activities. This could be new customer due diligence backlogs but also existing customers’ periodic reviews, trigger files and EDD files. We also remediate activities associated with ongoing customer management such as transaction monitoring, suspicious activity investigations and reporting, and customer screening activities for sanctions, adverse media and PEPs.
Q2. What are the various stages of preparing for a remediation project?
Before you even dream of starting a remediation, the big question is ‘What caused the remediation in the first place?’ You want to conduct a thorough gap analysis on two main elements. Firstly, ‘Is the current operational process fit for purpose?’ Secondly, ‘Is the data that you're working with in a fit state that can actually be used?’
Once you're done this you can then think about producing procedures, workflow and training materials, and putting together a test squad in order to run the process to make sure it works and you’re getting quality output from the start.
I guess for me, it's the planning piece - making sure you understand the root cause of the issue before you dive in, but also your plan of attack to resolve it. Without proportionate planning you don't set yourself up for success. Making sure you've understood the scale, timings, how long things take, and quantifying this into an actual plan in terms of how much resource you will need.
Q3. How do you take steps to ensure a remediation project is successful?
There are a few key aspects that you need to consider when approaching your remediation.
Open and clear communications with the team and keeping everyone updated on progress.
Setting process, procedures and goals from the start, which need to be well tested and robust.
Ensuring that targets are achievable and are tracked throughout.
Managing potential blockers quickly and effectively to stop bottlenecks.
Having brainstorming sessions with the team to get feedback on any improvements and embed if possible.
Q4. How does FINTRAIL ensure clients are in the best place during a project?
During the project we allow an element of flexibility in the resourcing. We offer flexible resourcing that can be scaled up or down as needed. It allows spikes to be managed before they get too high. Sometimes you need more staff to manage the alerts or manage the output itself.
Ultimately, it’s about working with the client to optimise processes, helping out on configuration activities to reduce false positives and be effective and efficient, whilst still identifying and managing the key controls and risks they need to look at.
Q5. Who manages the remediations projects and how do you ensure they are a good fit for your clients?
We have an experienced and pre-vetted bench of over 200 seasoned financial crime professionals ranging from operations managers and project managers, to analysts and investigators with FinTech, payments and banking backgrounds, across multiple jurisdictions and with a wide range of language capabilities. We maintain that bench on an ongoing basis with up-to-date CVs and targeted interviews to ensure everyone has the skills and experience that align to the project and the firm that we are working with.
Find out more about our remediation and flexible resource services and keep an eye out for more upcoming remediation guidance!
FINTRAIL has proven experience in leading and delivering remediation programmes and providing flexible resources across anti-financial crime programmes. Whether you need to redesign your target operating model, remediate due diligence files or deal with a spike in alerts, FINTRAIL can provide the expertise and resources to support your remediation.