Case Study

A Fortune 500 financial institution improves AML investigation productivity by 40%

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Client: A Fortune 500 bank holding company specializing in credit cards, home loans, auto loans, banking, and savings products

Business need addressed: Transform anti-money laundering (AML) operations to improve compliance with existing and new AML regulatory reforms, and remedy deficiencies identified by the Office of the Comptroller of the Currency (OCC)

Genpact solution: Genpact leveraged its AML center of excellence (CoE) to streamline and enhance the client's AML program while addressing key business priorities as outlined by regulators and internal compliance guidelines

Business impact: 40% productivity improvement, along with a reduction in alert ageing from 90 days to less than 50


A Fortune 500 bank holding company offering a broad array of financial products and services needed to transform its anti-money laundering (AML) operations. The firm's aim was to remedy the deficiencies identified by the Office of the Comptroller of the Currency (OCC), remedy historic transactions, and implement a centralized remediation process for transaction monitoring.

Business challenge

The financial services firm, with multiple lines of business spanning credit cards, auto finance, and consumer banking, was inundated with ever-increasing compliance-related challenges. New and existing regulatory reforms increased the need to build new compliance processes and infrastructure for enhanced risk management. Some of the key challenges that the firm faced were:

  • Regulatory authorities identified deficiencies in the firm's overall AML program
  • Compliance backlog of 400,000 transactions alerts
  • High ageing of alerts of over 70 days
  • Soaring volume of transactions and high manual intervention
  • Low productivity leading to higher cost per surveillance
  • Need to change existing processes to ensure compliance while minimizing complexity and optimizing costs

The firm consented to taking all necessary and appropriate steps to remedy deficiencies identified by the OCC in order to enhance its AML compliance program. To address these challenges, the firm chose Genpact as its strategic partner.

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Genpact solution

Genpact provided a multi-dimensional solution to enable the client to transform its AML operations. The solution encompassed:

Transaction monitoring remediation:

  • Genpact leveraged its Six Sigma and black belt certified quality team to conduct an assessment across different lines of business and identify gaps in the end-to-end AML process.
  • Based on the gaps identified, Genpact recommended and implemented a centralized and scalable alert-remediation process for effective transaction monitoring across different lines of business
  • 400,000 historic transactions were remedied in order to identify and report potential cases of money laundering

SEPSM-based process transformation:

  • Leveraged Lean/Six Sigma expertise and tools to standardize the remediation process across business lines, ascertain volume variances, and mitigate surges
  • Designed processes and documented detailed standard operating procedures (SOPs) for resolution and escalation of actual or partial false matches in line with client's procedural guidelines
  • Created a complete audit trail for the end-to-end remediation process, and implemented a process-benchmarking system to identify and eliminate bottlenecks

Quality control:

  • Created a repository to store records of all regulatory reporting, including a list of blocked assets, rejected transactions, and applications/grants of licenses, where applicable
  • Implemented quarterly refresher on domain trainings
  • Deployed failure modes and effects analysis (FMEA) for risk assessment at the process and project level to enable the client's team to identify potential failure modes, understand their effect on the process, and take immediate corrective action to de-risk the transaction process

Training:

  • Provided customized training to client's team detailing their responsibilities for AML process, and conducted in-depth training on the new AML transaction monitoring processes
  • Ramped-up training for AML alert processing and transaction monitoring, especially around US regulatory compliance, to understand the basis of suspicion, identify red flags, and conduct thorough analysis
  • Developed operational and strategic controls for the business
  • Implemented a multi-tiered tollgate-based training and assessment program for the investigators, lines of business, and work streams

Business impact

Genpact cleared the client's backlog as per regulatory timelines and is now supporting business-as-usual (BAU) alerts. In addition to enhanced compliance, the firm also achieved:

  • Zero backlogs within six months
  • Reduced alert ageing from 90 days to less than 50
  • 40% productivity improvement in end-to-end AML investigation work

Satisfied with the quality of service delivery over a span of two and a half years, the firm has since selected Genpact as a strategic partner for AML alert investigation and enhanced due diligence in the transaction monitoring space.

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