Scoping an AML Remediation Programme
A practitioner's account of the work done before the first customer file is opened: defining the population, agreeing the standard, sizing the capacity and writing down the assumptions that decide whether the programme is deliverable.
For Programme Sponsors, MLROs, Heads of Financial Crime, Remediation Programme Directors, Steering Committee chairs and second line oversight functions scoping a remediation before delivery begins.
Guide 009 sets out, decision by decision, the work that determines whether a remediation programme is deliverable. It separates scope, objectives and success criteria; defines the population with two reconciled queries against a single cut-off; segments the population by risk and treatment rather than by convenience; writes the file standard as a working artefact with worked examples; calibrates productivity on a fifty-file pilot per segment rather than from a benchmark; builds capacity in layers (effective working week, ramp-up, QA, attrition); names the governance the programme will be run through and the cadence it will report at; sets out mobilisation as its own costed phase; names the dependencies the programme cannot deliver without; sizes the contingency against the three specific assumptions most likely to move; writes down the success criteria before the work starts; and holds the whole plan together with an assumptions register that is rebuilt three times before mobilisation and re-tested at named triggers thereafter. Appendix A carries a working assumptions register. Appendix B carries the Steering Committee speaker brief.
Dentro encontrará
- What scoping is, and what it is not
- Defining the population: queries, cut-offs and reconciliation
- Segmentation, the file standard and the pilot that calibrates productivity
- Capacity in layers: working week, ramp-up, QA, attrition
- Governance, mobilisation, dependencies and the contingency conversation
- Success criteria written down before the work starts
- Appendix A: a working assumptions register. Appendix B: the Steering Committee speaker brief
This is the guide I would hand to the Programme Sponsor the week the remediation is approved, and to the Steering Committee chair the week before the scoping paper is tabled. It does not describe remediation in the abstract. It describes the work that is done before the first customer file is opened: the queries written, the population reconciled, the standard drafted, the pilot run, the capacity built in layers, the assumptions registered and the contingency sized against the assumptions most likely to move.
Fourteen sections, in the working order of a scoping. The first three cover what scoping is and how to write the objectives. The middle eight cover population, segmentation, the standard, productivity, capacity, governance, mobilisation and dependencies. The last three cover budget, risk and the success criteria the Committee approves before delivery starts.
Estructurado para ser útil, no para impresionar.
What scoping is, and what it is not
Defining the population: queries, cut-offs and reconciliation
Segmentation, the file standard and the pilot that calibrates productivity
Capacity in layers: working week, ramp-up, QA, attrition
Governance, mobilisation, dependencies and the contingency conversation
Success criteria written down before the work starts
Appendix A: a working assumptions register. Appendix B: the Steering Committee speaker brief
10 Questions Every Board Should Ask Before the Regulator Does
Ten Board-level governance questions, with a structured self-assessment and score guide.
Ver guíaIs Your AML Remediation Programme Set Up to Succeed?
Nine sections covering governance, quality assurance, MI, Board reporting and root cause analysis.
Ver guíaPreparing for an AML Inspection
Eight focus areas from governance and CDD through to evidence preparation, with a readiness score.
Ver guíaManaging an AML Remediation Programme
Fourteen working sections covering scope, governance, prioritisation, QA, MI, Board reporting and close-out.
Ver guíaBoard Oversight of Financial Crime
Fourteen working sections on what the Board owns, the papers it reads, the questions it asks and the decisions it cannot delegate.
Ver guíaPreparing for an AML Inspection
Fourteen working sections covering the notice letter, the document request, the data room, the interviews, the exit meeting and how to respond to draft findings without negotiating away the truth.
Ver guíaQuality Assurance During KYC Remediation
Fourteen working sections covering sample design, defect taxonomy, calibration meetings, trend reporting, re-review triggers, acceptance criteria and how QA supports governance rather than only measuring it.
Ver guíaBuilding Meaningful AML Management Information
Fourteen working sections covering the three lenses of activity, quality and residual risk, the five-question rebuild, KRIs and thresholds, the commentary discipline, escalation, the annual rebuild and how MI fails quietly.
Ver guíaSi no está seguro de si su organización se beneficiaría de apoyo externo, hablemos.
Si no creemos que Claritas sea la opción adecuada para su organización, se lo diremos con franqueza.