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The role of the compliance function is to support the business in managing risks arising from new and often complex regulations, and where possible, help identify and predict new compliance risks in good time. Transcendent Group’s consultants have extensive experience in working with regulatory matters.
Background
Over the past ten years the regulatory landscape has undergone significant change and has grown in complexity. This has created significant compliance challenges for both private and public sector organizations, in terms of achieving compliance with external and internal requirements without compromising agility and effectiveness. A strong compliance management is therefore essential for companies to increase their business efficiency while complying with requirements.
How we can help
Transcendent group has acquired significant compliance experience from many engagements, including a wide range of compliance solutions and implementations. This has given us a clear picture of compliance best practice and we are able to bring this to bear in new compliance projects with our clients. We have a strong focus on knowledge sharing and the provision of value adding advice to our customers in as an efficient way as possible. We focus on promoting conscious compliance models and data-driven solutions for our clients’ organizations, and we strive for the sound balance between control and risk.
Services provided
TG’s definition of compliance includes the risk of regulatory sanctions, financial or reputational loss arising from non-compliance with laws & regulations, internal and external requirements, ethical standards and market expectations. Our compliance services include the following:
Track record
Chief Compliance Officer
Client needed to fill an interim role as CCO. We supported the client with their needs and filled the role. We reported to the Group CEO and the Board of Directors and took responsibility for the whole second line work. We coordinated the different compliance activities (risk assessment, controls, monitoring, regulatory watch, training, etc.), established the annual plan and trained the team.
Compliance Gap Analysis
The client needed a gap analysis between various regulations (MiFID II, IDD, MAR, and AML mostly) and their own policies and processes. The challenge was to be able to consider several different regulations. We performed the gap analysis and trained the teams on the regulatory issues.
Compliance Monitoring
The client needed a compliance expert in monitoring activities. We supported them with their monitoring activities, by taking the lead in all the activities in the Compliance Plan, and by training the other Compliance Officers in the methodology, they would gain the necessary skills to perform controls themselves.
Financial Crime is defined as illegal acts committed by an individual or a group of individuals in order to obtain a financial or other type of advantage for themselves or others.
Financial crime is an operational risk that can be mitigated by a robust Governance, Risk and Compliance framework. A Fraud Risk Management (FRM) program should demonstrate adequate governance and internal control, and is typically defined by the phases Governance, Prevention, Detection and Compliance.
Types of Financial Crimes
The list of potential crimes that fall under this term is quite long: Corruption, embezzlement, environmental crimes, theft, fraud including CEO Fraud and more.
Transcendent Group Services
Transcendent Group can assess the maturity of an organisation’s Fraud Risk Management program, and also assess whether this is adequate for the risks facing the business.
Transcendent Group can also design an entire program or parts thereof, or other controls used to follow up the work against financial crime.
Transcendent Group can also execute functions such as program management, project manager or act as management for hire.
Transcendent Group is the home of Anti money laundering specialists with years of experience. Our approach is to tailor our offering to the clients’ need, size and circumstances. We work with clients across the spectrum of businesses that are subject to AML laws. We also work with vendors in the same space. Across a wide range of services we assist in evaluation, design and execution of work streams.
What we do
Gap Analysis
A GAP analysis is a review of a client’s AML program to identify whether there are areas where policies, procedures, systems and controls that require further enhancement to meet expected standards. Transcendent Group perform GAP analysis on all types of entities, local as well as multinational. We can assist in designing a GAP analysis performed by the business themselves, assess a previously done GAP analysis, and execute the entire GAP analysis for the client. Transcendent Group also has extensive experience in design and implementation of control measures against money laundering and regulatory compliance.
Some of the GAP analysis we do take place prior to a regulatory intervention, and some are done as part of reports to the corporate board.
AML Risk Assessments
The AML Risk Assessment forms a cornerstone of the overall AML program. The objective is to identify the inherent risks that the Client is exposed to, before assessing the quality of the risk management and mitigation controls that are in place. This leads to establishing the residual risk, and the identification of risk mitigating measures. Transcendent Group assess previously performed AML Risk Assessments, design the methodology to perform one and execute or assist in the execution of AML Risk Assessments.
Governance and Operating Models
The governance and operating models are management structures that are in place within an organisation to provide oversight, leadership and direction to the AML work. This includes what information (Management Information, or MI) that are required to understand and drive performance. Some businesses also feel the need for a structured overview of the current state versus the desired target state of AML Compliance in the organisation. A target operating model (TOM) shows the current state, the desired state and the necessary steps required to reach the desired state. Transcendent Group can perform assessments of the current state of governance, as well as establish a target state and build a plan for reaching this. We can also execute the plan. Transcendent Group can assist in an ongoing dialogue with authorities as part of an ongoing regulatory intervention.
Assurance and Internal Audit reviews
While similar in structure to a GAP analysis, the difference between a standard GAP analysis and an assurance review is often the requirement for a documented independent review. This need can be driven by an acquisition of a business or portfolio. Therefore, an assurance review may be a more comprehensive review, let us help you execute a complete assurance review.
Transaction Monitoring, Sanction Screening and Model Validation
Transaction Monitoring is defined as the identification of specific patterns that may indicate risk for Money Laundering or Terrorist Financing. Sanctions Screening is defined as screening customers and their transactions against sanctions lists. Financial firms also screen against lists of Politically Exposed Persons (PEPs) as well as news services in order to identify potential risks in their client base. The use of quantitative analytical model in AML decision-making imply a risk. Adverse consequences may involve false negatives as well as excessive amount of false positives. It may therefore be necessary to manage the risk inherent in the use of quantitative analytical models.
• Effectiveness reviews
It is a regulatory expectation that banks review the effectiveness of their transaction monitoring and sanction screening processes in order to ensure the systems remain up-to-date. This can entail a data quality review of the screening solution, a s configuration review and enhancement testing.
• Efficiency reviews
If the solution is not configured optimally, this can impact both operational efficiency and compliance costs. Transcendent Group can perform a review of the transaction monitoring and/or screening solution in order to identify potential areas for improvement, such as more effective us of automatic false positive elimination and enhanced list management, use of techniques such as machine learning that can improve processes without increasing regulatory risk while improving costs.
• Assessment of systems
As part of a system sourcing process Transcendent Group can assess systems available in the market and map these against the specific needs of an organisation.
Training
Training forms a cornerstone of any AML program, and must be adapted to the audience as well as dynamic – i.e. updated regularly. Transcendent Group can assess current training program, design various training programs for the clients as well as perform training, general programs or specialist training.
Remediation and Look back investigations
A Remediation (or re-papering) project is a historical review of the Client’s due diligence files to ensure current regulatory requirements are met. A Look back investigation is an investigation aimed at identifying previous sanction breeches or historical breeches against AML or terrorist financing rules. A look back investigation rarely aims at brining the due diligence of the client base up to current regulatory standards. Transcendent Group can design the projects or parts of the project involving remediation or look back investigation. In addition we assess planned or ongoing projects. Transcendent Group also provides functions within the execution of the projects such as project management and subject matter expertise.
How we deliver
Transcendent Group deliver our services on several levels.
Strategic partner
Transcendent Group can be a strategic partner, and act as a member of a management team and be involved in investment decisions. Transcendent Group also manages applications for licenses or authorisations.
Evaluate and assess
Transcendent Group can assess and evaluate procedures, projects or systems and provide recommendations.
Design and establish
Frequently, Transcendent Group designs and establishes procedures, documentation, projects and methodologies used by organisations as part of their work.
Execute
Transcendent Group may execute an entire project. This can be done during the set-up of a new business operation, as part of change management of an existing business or as part of a change or modification of existing systems or procedures.
Interim roles and co—sourcing
Our consultants can fill roles in an organisation as part of a management for hire arrangement, or as part of an outsourced service where Transcendent Group manages a compliance function.
Not sure where to start? Contact us and we are happy to help you define the needs of your organization. We can customize an offering to best meet the needs for your organization.
We want to know more about you and your organizations challenge! Get in contact with your local office to find out more about our culture and services.
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