Case study: KYC taskforce of eight compliance officers at a financial institution

The financial institution had to review and update client files as part of a KYC remediation. At the same time, transactions had to be analysed and alerts from transaction monitoring worked through.

Projects like this tie up far more capacity for a limited period than a compliance department holds for day-to-day business. Every review must be documented in a traceable way. The institution therefore opted for a taskforce with its own team lead and a clear reporting line to in-house compliance.

Alpinum Solutions presented selected compliance officer profiles within 48 hours. From these, a taskforce of 8 FTE including a team lead was formed, all full-time. The assignment ran as staff leasing, legally Personalverleih under Swiss law: the professionals were integrated into the institution's organisation.

Taskforce responsibilities

• KYC remediation and KYC file reviews
• Transaction monitoring and alert handling
• Documentation of reviews

How the institution steered the assignment

• Reporting line: the team lead reported to in-house compliance.
• Right to give instructions: the institution held the right to give professional instructions; standards, priorities and decisions on individual cases stayed with in-house compliance.
• Start: the taskforce began work around two weeks after the order.

Alpinum remained the point of contact for the institution and the professionals on contracts, terms and duration. The professional work was directed by in-house compliance.

The project was completed after 10 months. The taskforce handled KYC file reviews, transaction monitoring and alerts and documented its reviews. In-house compliance kept control of standards, priorities and case decisions throughout.

For similar projects, the case shows that a team lead with a clear reporting line to in-house compliance keeps control with the institution, even when several interim professionals work at the same time. How Alpinum supports KYC remediation projects with interim specialists is covered on the AML/KYC remediation page.