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.
How we implemented Risk Based AML, Sanctions & PEPs
To fortify the organisation’s regulatory posture, we initiated a comprehensive overhaul of the Anti-Money Laundering (AML) framework.
By establishing a rigorous performance baseline across all business lines, we successfully integrated a modernised AML Policy and a corresponding Global Operating Manual.
This strategic alignment was underpinned by the deployment of a sophisticated Customer Risk Assessment (CRA) engine, ensuring data-driven precision in both initial onboarding and lifecycle monitoring.
The project concluded with a full-scale forensic review of the existing client base, migrating all accounts to the new standard of excellence and neutralising legacy risk.
Changing how the Bank worked
improving the Customer Experience
Challenge
The business lines operating in different jurisdictions each operated its own AML procedures.
The Bank had to coordinate how AML procedures, data collection and verification, KYC evaluations and ongoing monitoring is carried out.
Each jurisdiction also had specific and unique requirements.
No central mechanism for sanctions, PEPs and monitoring transactions existed.
Solution
Facing a fragmented regulatory landscape, the organisation required a unified approach to financial crime compliance.
We led the end-to-end redesign of the KYC/AML architecture, developing a data-led specification for a future-state centralised customer data system.
By integrating a new Customer Risk Assessment tool and bespoke application protocols, we shifted the organisation from manual processing to a risk-based, tech-enabled onboarding model.
To drive fiscal efficiency, we offshored core data processing and monitoring to a specialised Canadian hub, achieving a leaner cost structure without compromising on jurisdictional integrity or policy adherence.
Jurisdictions
6
New Processes
237
New Data Capture
12
New Systems
8
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.