The challenge sneaks up on you, slowly: A regulatory amendment, expansion into a new jurisdiction or launch of a new product.  A pragmatic workaround is found, maybe some re-keying or an excel sheet to keep track. 

After a few years of iterative changes and workarounds, you find your organisation in a bit of a mess.

You are not too smart to not invest in intelligent onboarding.

I hate being ‘onboarded’ in my private life…the process is driving me mad

Just think for a second about the pain of having to be onboarded in your personal life – taking out a new pension, mortgage, or setting up a new bank account (have you seen the new FACTA questions?).  Copy of passport, utility bills, forms to sign, etc. 

It is painful, but thankfully, new, emerging consumer FinTech’s are making it easier (and even some less agile institutions have found new ways due to the pandemic).

Now think about the process of onboarding your clients at work…    

Most likely your onboarding process has grown organically.  First an excel file with data, then a few dedicated team members, then one and then two systems…then another team.  With more stringent regulations, you suddenly have a process that can take 3 to 6 weeks, is costly, and error-prone.

There is a plethora of regulation that must be considered during the customer onboarding and monitoring process, these include KYC/AML, FATCA, EMIR, and MiFID II to name but a few.

It is serious: ‘Money Laundering and Terrorist Financing…’

The Money Laundering and Terrorist Financing…’ (Amendment) Regulations 2019 came into force on 10 January 2020.  The language makes plain that this is serious; customer KYC/AML processes are at the heart of this.  

The FCA, in general, favours a risk-based approach, focusing on the outputs rather than specific AML laws and rules; “firms must have in place policies and procedures in relation to customer due diligence and monitoring, among others, but neither the law nor our rules prescribe in detail how firms have to do this.”

Are you confident that your staff are complying with the agreed internal processes?  Email and excel do not deliver a robust audit trail.

At some point, regulators will stop tightening the screw…right?

The 2019 Money Laundering and Terrorist Financing amendment was just the most recent turn of the screw.  Since the first meaningful anti-money laundering initiative was kicked off in 1989 when a group of countries worldwide formed the Financial Action Task Force (FATF), the pace of regulation has accelerated.  The 1989 initiative was first incorporated into UK law via the Criminal Justice Act 1991, the Drug Trafficking Act 1994 and then into the Money Laundering Regulations 1993. 

History tells us you need to be prepared for further tightening by regulators (who are increasingly cooperating via data sharing arrangements).

At the same time, your organisation is likely to look for new pools of capital or to manage new products (crypto-related assets is another gamechanger).  

Further cost explosion – or risk the ‘Go to Jail’ card? 

Unlike Monopoly, where being sent to jail is decided by the throw of the dice, in the real world you can obviously protect yourself.  But this protection is costly: The financial services industry has seen the costs of compliance almost double since 2017 as these regulations have continued to evolve.

‘I am implementing a new system to fix it forever…’

Unfortunately, there is no ‘one magic bullet’.  Software vendors will suggest that their solution has all the features required to fix your problem.  The reality is that client onboarding and monitoring is a moving target. 

You need to be agile.  A data-driven approach to client onboarding and lifecycle management is more important than ever.  The implementation of smart technology and automation is a game-changer delivering accuracy, security, and operational efficiency across the value chain.  It also enables a better client experience in an increasingly competitive world.

What is Intelligent Onboarding? Don’t rip out and start from scratch!

You have already invested in people, processes, and systems.  Don’t throw all of this away but look to insert intelligence into your exciting processes.  How?

First, focus on connecting and enhancing existing processes and systems.  We think about using software as intelligent glue to avoid repetitive manual processes (which also creates better data and a proper audit trail).

Second, look to leverage smart 3^rd party API services. Intelligent Onboarding is a framework to help you leverage existing (and future) services and pick the right items (or those that are currently not part of your process) such as biometric authentication for onboarding institutional clients, automatic UBO lookup, or new services scanning for adverse media coverage or politically exposed people.

There is a smarter way of doing it. Contact us for a demo on Intelligent Onboarding and learn how it can be deployed in 90 Days.

David Landi – Capital Markets Lead

 Email: david.landi@pskinetic.com

 LinkedIn:
www.linkedin.com/in/david-landi/