Whenever there are multiple individuals involved in the same customer case, there is a loss of time, because each individual use some “base-time” to get acquainted with the case, even if they have different roles in the process.
At the same time it is difficult for a single person to understand and master all process steps, so designing the optimal process becomes a balance between the advantages of specialisation and the time lost by having too many handovers.
The first thing to do is to measure how many people are involved in the same customer case. For illustrative purposes, I will use a customer case that theoretically could end up with too many people involved: There is a TM alert on a low-risk customer that leads to a SAR as well as an upgrade of the customer to high-risk and finally a decision to exit the customer.
The flow might be: The TM 1st level escalates to TM 2nd level that escalates a UAI (internal SAR) to an MLRO that creates the SAR to the authorities. This results in a KYC analyst conducting an EDR resulting in an exit recommendation, where yet another person is handling the practicalities. That is “only” 5 individuals.
However in the financial crime prevention process flows, there are also often 4-eyes and/or team leads involved to secure the needed level of quality. That is potentially 10 additional individuals and having 15 people and on top also the customer exit committee with several members involved in the same case is for sure overkill.
My advice is that you aim at reducing the number of people involved in each customer case, but you do a thorough and differentiated implementation, guided by the development in the quality KPI.
Firstly, differentiate the involvement of 4-eyes, so analysts and TM investigators with proven quality track record is only subject to the normal parallel sample-based quality control process, while new individuals need the 4-eye until they also have a proven quality track record.
Secondly, involve the team leads effort only in the sample control process instead of in the daily 4-eye flow.
Thirdly, consider if TM Operations 2nd level can file SARs directly, thereby eliminating all UAI’s/internal SAR’s. Use the number of UAI’s/internal SARs that was rejected or improved by the MLRO as the starting point for a differentiated implementation.
Regardless how many handovers you manage to reduce, you will still end up having several persons involved, so make sure each role is very sharply defined, thereby keeping duplication of the same task to a minimum.
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