CHANGE: Anti-Money Laundering Change programme
CLIENT: Butterfields
- Anti-Money Laundering business and technical implementation and AML Policy revision
- Multiple jurisdictions (Bermuda, Cayman Islands, Guernsey)
- Business operating model implementation
- Offshore (Canada) operations centre implementation for monitoring, checking and reporting
The Client Position
The revision of AML regulations in the Overseas Territories to align with UK regulations required changes to the processes, data capture, storage and transaction monitoring across all Bank businesses and jurisdictions.
What the Client Said
Stephen worked with us through the referenced period, involved in various aspects of evaluation and implementation of 1st line of defence Compliance Roadmap/KYC/AML programmes. This included the coordination, tracking project management and related documentation development, as well as participation in the buildout of an in-sourcing (alternate jurisdiction) arrangement.
Stephen demonstrated a high degree of professionalism and diligence at all times, effectively working across a number of Butterfield’s key banking business lines, and with a variety of individuals – from administrators to senior executives. I have no hesitation in recommending Stephen.
Sean Smatt - Executive Vice President & Group Head, International Corporate Banking (Butterfields)
The Need
An experienced consultant to lead the change of AML business operations, processes and tooling to ensure that teh business was able to comply with the revised AML regulations coming into force for overseas territories for their Corporate, Retail, Private Banking and Trust businesses in Bermuda and the Cayman Islands.
The Approach
- Redesign of the AML approach including jurisdiction and business type specific policy revision
- Design and delivery of a suite of application forms forming a specification for central systems development
- Process changes to execute the policies and creation of an offshore operations centre in Canada to perform cost effective data processing, sanctions checking, monitoring and reporting.
The Outcome
- AML revisions successfully enabled the Bank to meet new regulations.
- The introduction of automated systems and off-shore processing reduce operational costs.
- Revised data capture capability provided the basis of new AML Platform.
The Value
- Delivery of new customer data capture capability across all businesses and efficient KYC, sanctions and transaction processing enabled AML regulatory requirements to be met.