Case Study
offshore Anti-Money Laundering transformationThe oldest bank in Bermuda, Butterfield provides services for private and corporate banking, trusts, and investments.
The bank currently conducts business in Bermuda, the Cayman Islands, Guernsey, Jersey, Switzerland, The Bahamas, Singapore, and the United Kingdom.
For more information about Butterfield, click here
Intro
How we Implemented a consistent risk based approach to AML
To enable the update all of the AML related data, processes, controls, and risk assessments we established a baseline for each business line.
A new AML Policy, supported by an Operating Manual was implemented.
A new Customer Risk Assessment tool enabled appropriate onboarding and ongoing monitoring of the account(s) based upon a set of AML Policy risk factors.
All existing Customers were tested against the new standard and remedial actions taken where necesssary.
Details
changing how the bank worked and, improving the Customer experience
Challenge
There were several business lines operating in different jurisdictions, each of which had its own AML procedures in place.
The Bank had to coordinate how AML procedures were carried out, data is collected and verified, KYC evaluations are completed, and ongoing monitoring is carried out.
Local requirements unique to each jurisdiction also required to be taken into account.
There was no central mechanism for checking sanctions and monitoring transactions.
Solution
Redesigned the approach to KYC / AML processes incorporating jurisdiction specific requirements, business line and product specific policy guidance.
Based on the policy, a revised risk profile was defined; a new customer Risk Assessment Tool was developed to guide onboarding and ongoing monitoring requirements.
Design and delivery of a suite of application forms forming a specification for future development of a centralised customer data system.
New operating model implemented across all jurisdtions to ensure confomity to the revised AML policy.
Creation of an offshore operations centre in Canada to perform cost effective data processing, sanctions checking, monitoring and reporting.
Processes
237
jurisdictions
6
New Data Capture forms
12
New Systems Implemented
14
Testimonial
Stephen worked with us involved in various aspects of evaluation and implementation of first line of defence Compliance Roadmap/KYC/AML programmes.
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 (Butterfield)