Readying a top US bank with new policies, procedures, processes, and system requirements.

The Challenge

Complying with pending regulation

The Financial Crimes Enforcement Network (also known as FinCEN) has published the final beneficial ownership rule as an expansion of Customer Due Diligence. The rule mandates that all financial institutions identify ultimate beneficial owners and a control person of entity accounts as part of CDD by May 11, 2018. This new rule requires modified policies, processes, procedures, and supporting technology for onboarding new accounts. Accordingly, the bank wanted to:

  • Determine the impact of regulation on its business 
  • Revise its policies and procedures to comply with the new rule
  • Define and implement system changes to capture required data

The Solution

A collaborative approach to defining policy, process, and system changes

To prepare for the Beneficial Ownership regulation, the bank worked with a team from West Monroe Partners that provided the right blend of financial services regulatory experience and technology expertise. That experience includes assisting multiple top-50 US financial institutions with bank-wide implementation of the new regulation.

Recognizing that the regulation’s increased data collection requirements would affect lines of business differently, the project team analyzed data from a sample of accounts and defined the impact for each line of business. The team then worked with the bank and its front-office stakeholders to update policies and procedures related to account opening and maintenance practices to ensure they comply with the new rule. 

The project team then defined the system and process changes to onboarding and record systems to allow the bank to capture required data. This collaborative effort involved working with front office stakeholders across all lines of business, as well as with the IT function, to ensure the changes meet the needs of all parties. This step was critical given that the bank serves a wide array of clients,ranging from exempt organizations to complex ownership structures.

The Impact

Well-prepared for change and compliance

This collaborative approach enabled the bank to define business and system requirements related to the FinCEN Beneficial Ownership regulation in a timely manner – thereby enabling it to proceed with making the changes necessary for compliance. Just as important, by engaging business stakeholders in the process, the bank promoted greater understanding and acceptance for changes in policies and procedures across front-office functions.


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