Partway through the implementation of a financial crime risk management insights framework with a client, we discovered that:
- A significant financial crime risk data input system was in scope to be replaced without buy-in from all end users of the system.
- A significant number of existing and planned MI insights would not be available in the short to medium term resulting in manual workarounds for the financial crime teams impacted.
- Those previously available insights would now be manual instead of being automated directly from source system.
- The additional resource requirement was not aligned with existing staffing levels within the firm.
- Most downstream data feeds would be impacted by this change.
- The vendor’s implementation team were working to an off-the-shelf rather than targeted implementation. Assurances to senior management of the same data provision as before without the analysis to support such claims proved to be unfounded.
- To address the challenges, Beyond MI were able to leverage their tailored data dictionary to establish all data points sourced from the system and produce specific data requirements to the vendor.
- This ensured that the Financial Crime function had:
- a seat at the table to set specific requirements to ensure that all processing and insight capabilities were captured.
- MI and other data requirements were included within the minimum deployment criteria to ensure that data feeds were in place and tested prior to system sign-off.
- Critically, the Financial Crime function could then work with the vendor implementation team to:
- parallel run old and new system outputs to ensure consistency and accuracy of data produced.
- establish a data ownership model for ongoing provision of financial crime related data.
- establish data quality control points for existing data provision and planned enhancements.
The implemented solution has resulted in significant positive outcomes for the client:
- Uninterrupted provision of critical data from source system to MI reporting for Board, ExCo and MLRO.
- Continued insights into the quality of data contained within management reporting.
- Diligently planned data provision working from the Beyond MI established data dictionary for complete and accurate provision of data from source systems.
- All financial crime processes and downstream users of data being aware of the changeover and planned accordingly.
- Financial crime function inclusion in firm’s change control processes.