Conducting a Review of the AML/CTF/KYC Functions of a Multilateral Development Bank and Providing Improvements
New Link helped develop 3 strategies for a Multilateral Development Bank to help identify money laundering and terrorist funding, reviewing their AML/KTC/KYC technology, and finally delivering those investigations to the key stakeholders.
Problem Statement:
Task 1: Conduct a business review and the operations for a Multilateral Development Bank to identify money laundering and terrorist funding. New Link Consulting resolved this using methods like:
- Hosting interviews with stakeholders to understand AML/CTF risks
- Review functions to track what can be improved
- Prepare presentations to understand what can be enhanced
- Draft a report that includes actionable recommendations
Task 2: Conduct a review of the AML/CTF/KYC technology used by the bank. Included tactics being:
- A document review of the Bank’s technology
- Interviews to understand the procsesses involving technology
- Performing a GAP analysis for current technologies applied to AML/CFT/KYC risks
- Overview of how the technology is applied
- Recommendations on how to improve the technology
Task 3: Presentation of Investigation to the Consultant Working Group and Senior Management of the Bank.
NLC Engagement:
New Link Consulting deployed AML/CTF/KYC experts to the project, led by the Head of the AFC Practice. They intended to produce results (agreed to by key stakeholders), including tactics like:
- Produce function maps of AML/CTF processes, including onboarding and perodic review
- High level ML/TF Risk assessment as well as assessing the inherent and resiual risks
- Review all relevant documentation and recommend enhancements were necessary
Outcome:
Task 1:
There were a set of recommendations proposed by New Link to enhance the AML/CTF risk-based approach. It identified gaps and required facets which were lacking in the fields of 1st and 2nd line of defence and operational linkages/consequences. Improvements to these were included.
The processes needed to fill the gaps in the Bank’s components that were lacking in AML/CTF efficiency was provided as well as identify future challenges. These challenges in AML/CTF needed to be prepared for by the Bank (including dimensions related to donor countries’ changing regulatory standards and new financial crim typologies).
Task 2:
New Link produced a technology report that encompassed a high-level overview/mapping, gap analysis, benchmarking, and improvements on the use of technology for the Bank’s medium Capex plans.
Task 3:
There were a series of presentations of findings to key senior stakeholders as well as providing a report for future improvements to the RBA and Operating model.
