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Anti-Money Laundering Compliance
Risk & Advisory Services
Private & Confidential
Page 2
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
BMR Advisors
One
Microsoft
Tax & Advisory
Risk & Advisory
Mergers & Acquisition
Legal Support
Deliveredin 40+
countries 7 Locations
USA
Largestclientbase
3 Centersof Excellence AlliancePartners 40+ Partners
Global Delivery Advantage
600+
Employees
Experts &
experienced
consultants
750+ clients
engaged
Tier 1
Ranked Tier 1 in ITR’s
World Tax 2014 guide
to the world’s leading
tax firms
250+
Fortune 1000 clients
served
Right-Shoring
Choice of on-ground &
offshore
BMR was founded
in 2004 by a
group of former
Arthur Andersen
and EY partners.
We are now
recognized as one
of the top 5 firms
in India
Chartered Accountants,
MBAs, CPAs, ACAMS, ACL
Specialists, SAP
Specialists, CISA, CCISPL
and CFE
Ranked as a leading tax law
firm by The Legal 500, Asia-
Pacific Guide 2013
2+ million hours
delivered to date
Rated as a Great Place to Work
in India
Extensive engagements in
AML, KYC and Analytics for
Global Clients
Industry Focus
Energy, Financial
Services, Retail
Technology, Media,
Communications,
Infrastructure, Real
Estate & Japanese
Business Group Rated third most active transaction advisor in India by
VCCedge League Table for FY2013
40%
professionals
abovemanager
level
BMR Advisors
Private & Confidential
Page 3
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Our Services
Risk & Advisory
•Process &
Performance
Improvement
•Risk & Control
•Due Diligence
•Analytics
•AML & Financial
Compliance
Direct Tax
•Transfer Pricing
•Tax Litigation
•Transaction Tax/
Restructuring
•Corporate &
International Tax
•Expatriate Tax
•Tax Policy &
Advocacy
•Tax Outsourcing &
Compliance Services
Indirect Tax
•Advisory
•Compliance
•Litigation
M&A
•Corporate Finance
•Transaction Support
•Transaction Tax/
Restructuring
•M&A Legal
Legal Support
•M&A Support
•Direct Tax Litigation
•Indirect Tax
Litigation
•Advocacy
•Documentation
Japanese
Business Group
Retail Energy
Financial
Markets
Technology Media Real EstateManufacturing
Process Financial Legal Structuring Tax
CompetenceServiceLinesIndustry
BMR Advisors
Private & Confidential
Page 4
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Strategic Partnerships & Recognitions
Ranked second Most
Active Transaction
Advisor (Private Equity)
by Venture Intelligence
League Table for Q1
2011
Rated as a Great Place
to Work in India, 2010
Great Place to Work ®
Institute
Rated Tier 1 Tax
Transactional Firm for fifth
consecutive year by
International Tax Review’s
online poll, 2012
BMR ranked sixth (by
deal count) in Thomson
Reuters Mid-Market
Insight, Jan-Sep 2012
Rated third most active
transaction advisor by
Venture Intelligence
League Table for the first
half of 2012
BMR Legal Ranked
among the top Indian
legal tax firms by the
Chambers and Partners
in the Asia-Pacific Guide
2012
Rated Tier 1 Tax
Transactional Firm for
sixth consecutive year by
International Tax Review’s
online poll, 2013
BMR Advisors ranked third
leading financial advisor in
India for the year 2012 by
Thomson Reuters Mid-
Market survey
BMR Advisors rated as
Number One transaction
advisor by VC Edge for the
year ending 2012
BMR Legal ranked as a
leading tax law firm by
The Legal 500, Asia-
Pacific Guide 2013
Ranked as a Tier 1
Firm in India,
International Tax
Review, World Tax
Survey 2009
2009 2010 2011 2012 2013
Ranked Tier 1 in ITR’s
World Tax 2014 guide
to the world’s leading
tax firms
2014
BMR Alliance Partners
2015
Ranked Tier 2 in ITR’s
World Transfer Pricing
2014 guide
Most Active transaction
advisor for Private
Equity and M&A by
Venture Intelligence
Ranked Tier 1 in ITR’s
World Tax 2015 guide
to the world’s leading
tax firms, 8th year in a
row
Ranked Tier 2 in ITR’s
World Transfer Pricing
2015 guide
BMR And Community
The firm has a strong commitment to community service. As much as client service, we endeavor to fulfil our social responsibility under the
aegis of BMR Foundation. Through our ‘Go Green Initiative’, we adopt environment-friendly practices at our workplace. We actively support
initiatives such as SOS Children’s Villages of India, Indian Red Cross Society and MillionTreesGurgaon.
BMR Advisors
Private & Confidential
Page 5
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Our Clients | Financial Services
Asset Management
AIG
Fidelity
ING
JP Morgan Chase
Templeton
Banking
ABN AMRO Bank
AIG
American Express
Bank
Barclays
Bank of America
BNP Paribas
Citigroup
Corporation Bank
Deutsche Bank
HDFC Bank
HSBC
IDBI Bank
ING Bank
JP Morgan Chase
Ratnakar Bank
Royal Bank of
Scotland
State Street
Standard Chartered
Sumitomo Mitsui
Banking Corporation
Templeton
Toronto-Dominion
Toyota Financial
Services
Insurance
Birla Sun Life
Insurance
ICICI Prudential
ING Vysya
PNB MetLife
Baer Capital
Blackstone
Carlyle
CVC
Englefield Capital
GIC
Helion Ventures
Henderson
Halcyon
ICICI Ventures
IDFC Private Equity
India Value Fund
Lazard
Mandala Capital
Motilal Oswal
New Vernon
NVP
Och-Ziff
Old Lane
Q Investments
Sage
Shriram Transport
Finance
Temasek
Warburg Pincus
Real Estate Funds
Actis
Aditya Birla Real
Estate Fund
Ascendas
The Chatterjee Group
IREO
Deutsche Realty
Kotak Realty
New Vernon Realty
Red Fort Capital
Solitaire Capital
Investment Banks
ADM Capital
Citigroup
Credit Suisse
Deutsche Bank
Merrill Lynch
NM Rothschild
Goldman Sachs
JPMorgan
Lehman Brothers
Morgan Stanley
UBS
Private Equity
Alchemy Partners
Apollo Investment
Corporation
BMR Advisors
Private & Confidential
Page 6
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Our Clients | Non-Financial Services
24/7 Customer
ABB Group
Accenture
Actaris
ADM Capital
Airtel
Airwide solutions
Alstom
Apple Computers
Assa Abloy
AstraZeneca
Avaya
BAF
Baker Huges
BD
BEA Systems
BHP Billiton
Biocon
BlueDart
Blue Foods
BP Amoco
Brightpoint
British Gas
Broadcom
Cadbury Plc.
Calleo
Canon
Cargill
CGG
Chevron
Cisco Systems
Claris Lifesciences Limited
CNBC
Continental Airlines
Dabur
Daikin
EagleBurgmann
Enfield
Enpro Jubiliant
Equant
ExxonMobil
Fujifilm India
General Motors
Genpact
Goodyear
Gujarat Gas
GIC
GMR Group
GSK
HDFC Chubb
Helmerich & Payne
Heidelberg Cements
HP
Hutch
IBM
ICA Domus Trust
Indigo Airlines
Ingersollrand
Intel
Interglobe Enterprises
Itochu Corporation
Ivy Comptech
K Raheja Corp.
Kennametal Widia
Kobelco Cranes
Kodak
Lear Corporation
Levi Strauss
McKinsey & Co.
Metal One
Mindtree Consulting
Mitsubishi Corp
Mitsubishi Material
Mosbacher
NCR Corporation
NDS
Nokia
Novartis
Novo Nordisk Premier Oil
Oxigen
Panasonic
Pepsi
Perot Systems
Petronas
Quest
Radhakrishna
Reuters
Regulatory Data Corp
Reliance Industries Ltd
Rolex
Samsung
Sanyo
Schlumberger
Shell
SIA Engineering
Socomec
Sojitz
Sony
Star TV
Sumitomo Chemicals
Sumitomo Corporation
Suzuki
Synova
Tally
Teletech
Ten Sports
Texas Instruments
Thomson
Uni Products
USV
Valtech
VSNL
Xerox
Yum!
BMR Advisors
Private & Confidential
Page 7
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Risk & Advisory | Key Services
Anti-Money Laundering
Anti-Bribery Compliance
Intellectual Property Monitoring
Risk
&
Advisory
Data Analytics
Process Development & Optimisation
Internal Audit
Process Integration
Securitization Support
Data Assets
Impact Analysis
Fraud Investigations
Fraud Assessment & Prevention
Fraud Analytics
Financial & Tax
Business Analysis
Third Party Ecosystem
Risk Management Framework
Online, Mobile & New Age Crimes
Risk & Advisory Services
Private & Confidential
Page 8
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Internal
Controls
Management
Oversight
Standards
Risk Based
Framework
Remediation
&
Refinement
Transaction
Monitoring
KYC Due
Diligence
Training Screening
Policy &
Procedures
AML Technology
Support
Agent
Network
Assessment
Independent
testing
AML
Diagnostic
Check
Our Anti-Money Laundering Compliance
offerings have been structured to ensure
complete coverage of all aspects of the
present & emerging compliance
challenges.
These offerings have been divided into
AML Support
AML Core
AML
Investigation
Anti-Money Laundering
Anti-Money Laundering Compliance Services
Private & Confidential
Page 9
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Program Management
►Diagnostics
►Risk based framework
Operations
►KYC Remediation
►AML Hub
►Process Design & Training
►Threshold Review
►Alert Disambiguation
►Data Analytics
Our AML solutions take a modular
approach, interfacing with relevant
components of the organization’s AML
compliance framework
BMR - AML Approach
The BMR AML Solution Components
Private & Confidential
Page 10
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Set-up & Operation | Global KYC CoE
Business Issue
► To address the identified
anti-money laundering
compliance deficiencies that
affected banks’ business
► To complement the
Compliance department’s
roll out of its new KYC due
diligence process/ Customer
Acceptance Forms
Region(s)/Countries
► 229 jurisdictions globally
What BMR did
Determined:
► Unique set of customers for
each different business unit
► Existing customer
information gaps
► Project schedule and effort
estimates
► We developed a ‘One Team
Structure’ with multiple
personnel
► Successfully managed the
entire back-end for 229
jurisdictions and performing
customer due diligence for
225,000 corporate customers
► Our operations team
performed – background
verification, name and news
screening, sanction list
checking, external research
and fulfillment of local
country requirements
Key Benefits
► Addressed the timelines set
by the Regulators for KYC
remediation of customers
► A global KYC Repository –
for future use
► Quality function introduced
in the COE to ensure
consistence delivery
standards
► Allowed the bank to focus
on key AML issues; limit
disruption to business; meet
the milestones provided by
the Regulators
► Educated the team in
Mumbai, on KYC
documentation and data
management
Key Deliverables
► Implemented a global KYC
Hub – successfully
managing the entire back-
end KYC processes for 229
jurisdictions
► Developed Standard
Operating Procedures,
thereby defining clear
roles and responsibilities
► Designed IT Solutions for
Data Management
► Comprehensive Training
Manual for the
Operations, developed
and training imparted to
the all team members
► Developed a Risk and
Control Self Assessment
(RCSA) for documenting
the Risk and Control
framework for the COE
AML Projects & Experience
Private & Confidential
Page 11
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Business Issue
► BSA and USA PATRIOT Act:
International FATF
Recommendations and US
legislative regulations
mandate a financial
institution to conduct
appropriate risk-based due
diligence on a potential
client prior to engaging in a
business relationship
► Bank had engaged BMR &
Partner Firm to conduct the
KYC Remediation of the
India domiciled accounts.
Region(s)/Countries
► APAC
What BMR did
► Identified the customer on
the basis of documents,
data or information
obtained from a reliable and
independent source
► Identified, where applicable,
the beneficial owner and
took risk-based and
adequate measures to
understand the ownership
and control structure of the
customer
► Obtained information on
the purpose and intended
nature of the business
relationship
► Identified gaps and
recorded requirements in
pre-defined templates
► Conducted sales connects
► Management Reporting
Key Benefits
► Facilitated the bank to know
who they are doing business
with in a bid to prevent the
bank from inadvertently
facilitating money
laundering
► Facilitated the compliance
to the RBI requirement
► Developed Daily and weekly
MIS dashboards, with
various information cuts, to
report status to
management as per their
requirement
Key Deliverables
► KYC due diligence and gap
analysis of over 800
accounts over a period of
6 months
► Sales connects with
relationship managers
along with status of the
connects
► Filtering documents stored
on the shared drive to
ensure only most updated
documents are retained
AML Projects & Experience
KYC Remediation | APAC operations of a Wall Street Bank
Private & Confidential
Page 12
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Business Issue
► High volume of monitoring
alerts causing difficulties in
identification of suspicious
transactions
► To expedite the alert
disambiguation process,
identify false positives and
increase review
effectiveness
Region(s)/Countries
► Americas – NY
What BMR did
► We assisted the client in
optimizing their automatic
transaction monitoring
thresholds by:
• Identifying anomalies in
transaction behavior
• Detecting hidden
relationships and linked
accounts
• Identifying beneficial
ownership of transactions,
and
• Analyzing segmental
characteristics, based on risk
profiling
► In addition, we assisted our
client in establishing
effective AML alert
disambiguation processes
using KYC information and
customer transaction history
Key Benefits
► Reduced false positives
► Timely and accurate alerts
► Identification of suspicious
relationships
► Identification of beneficial
owners
► Consolidation of the
detection process across
multiple channels
Key Deliverables
► Established effective AML
alert disambiguation
processes
► Training on alert
disambiguation
procedures
► Dry runs and
implementation of
disambiguation processes
► Optimisation of the
automatic transaction
monitoring thresholds
► Risk profiling of customers
AML Projects & Experience
Transaction Monitoring Optimization | Wall Street Bank
Private & Confidential
Page 13
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Business Issue
► BMR was tasked by one of
the top 5 global banks to
objectively evaluate,
independently test and
perform an assessment of
the bank’s existing AML
policies, procedures,
systems and internal
controls for compliance with
relevant AML regulations
and regulatory expectations
Region(s)/Countries
► Bangladesh, India, Malaysia
What BMR did
► A review was conducted
both within the context of
the compliance regime of
the country and international
standards.
► As the Bank conducted a
high volume of US Dollar
denominated transactions
and had a subsidiary network
outside the country, reviews
were conducted in
accordance with global
guidelines
► Our work included interviews
and discussions with key
departments and staff
members to determine key
action areas and solutions
with the goal of addressing
any AML compliance gaps at
the banks.
Key Benefits
► BMR independently tested
the effectiveness of the
bank’s implemented AML
program from the strategic
policy and operational
perspective
► Reported and remediated
gaps identified
► Provided more comfort to
management on the AML
function within the bank
Key Deliverables
► Gap report with
recommendations for
plugging the gapsAML Projects & Experience
AML Reviews | CB Partners of global bank post regulator intervention
Private & Confidential
Page 14
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Business Issue
► To develop a comprehensive
PEP database in compliance
with Anti-Money Laundering
(AML) regulations such as
Anti-Bribery Act (ABC), US
Foreign Corrupt Practices
Act, US Patriot Act etc.
► To enhance the customer
due diligence process with
the development of the
aforesaid comprehensive
PEP database
Region(s)/Countries
► More than 240 counties
What BMR did
► Designed political Structures
to holistically capture the
PEP definition (global and
country specific)
► Risk based Scoring Model to
categorize PEPs, their close
associates and family
members
► Sourced Information
pertaining to PEPs from
multiple sources such as
government bodies, news
article, databases etc.
► We performed periodic
reviews and assessment of
all in-scope countries to keep
the developed database
updated
► Developed MIS and reporting
matrices
► Training manuals and SOP
Key Benefits
► Exhaustive database with
global coverage of Political
Public Figures
► Standardisation of PEP
definition, processes across
42 countries, taking into
account differing local
regulations
► Micro- categorization to
distinguish between
international, national and
local PEPs
► Risk rating to easily view
high risk PEPs
► Periodic reviews to maintain
countries with current
political updates
Key Deliverables
► Extensive due diligence
report with respect to
client’s requirement for
250K+ profiles
► Unified research platform
containing complete
associations of Political
public figures
► Standard Operating
Procedures (SOP) and
Reporting framework
► Weekly and monthly
updates on changes
observed in countries
political events
AML Projects & Experience
PEP Review & Build-out | Global PEP repository for 240 countries
Private & Confidential
Page 15
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Business Issue
► To conduct due diligence
based on the global FATF
anti-money laundering
(AML) requirements and the
Wolfsberg Principles for
Correspondent Banking for
15K banks
► To create a database for all
these set of banks with the
required set of documents
► To create an online platform
to integrate all the research
findings for these banks
Region(s)/Countries
► Across multiple geographies
globally
What BMR did
► We identified and developed
a database for sources such
as stock exchanges, company
registries, news websites etc.
(primarily public sources)
► Designed a Correspondent
banking due diligence form
► Conducted extensive
research and created a
database on Correspondent
banks that included -
ownership structure,
management details,
regulatory status,
correspondent banking
certifications
► Developed Standard
Operating Procedures and
Training manuals
Key Benefits
► Robust case management
capability with full audit trail
and all supporting
documentation
► Exhaustive database
incorporating data
aggregated from multiple
sources
► Comprehensive listing of key
websites to be screened on
a periodic basis for updating
information
► KYC due-diligence
documentation in respective
CADD forms
► Development of an online
platform
Key Deliverables
► Comprehensive decision-
ready reports on banks to
provide assurance and
protection against
anticipated regulatory
requirements such as US
Patriot Act, FCPA, Anti-
Bribery Act, KYC etc
► Standard Operating
Procedures (SOP)
► Comprehensive database
with set of supporting
documents for each bank
► Risk assessment report
► Weekly Project updates
AML Projects & Experience
Due Diligence | Developing a data set for Correspondent Banks
Private & Confidential
Page 16
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Business Issue
► To execute integration of
processes after a significant
Hedge Fund acquisition
► Comply with the US Know-
Your-Customer (KYC)
regulations regarding on-
boarding of customers, in an
accelerated manner
Region(s)/Countries
► Americas
► Western Europe
► Asia-Pacific
What BMR did
► We developed the project
plan; communicated and
obtained the buy-ins from all
locations
► We conducted background
checks to identify Senior
Public Figures and Politically
Exposed Persons and
delivered a Customer Risk
Matrix summarizing the
percentages of customers at
different levels of risk
► Our due-diligence specialists
conducted the on-boarding
due-diligence for 3,500
customers across 7 locations;
complied with the US
regulatory guidelines and
met the project timelines in
spite of all the involuntary
obstacles
Key Benefits
► Access to multi-disciplinary
team that provided
assistance in process
alignment, testing of the
Technology platform, due-
diligence of customers,
project management and
reporting on this significant
integration effort
► Allowed the bank to focus
on key operational and
integration issues; limit
disruption to business; meet
the merger milestones
provided to investors
► Educated the teams across 7
locations globally, on due-
diligence documentation
during a customer on-
boarding process
Key Deliverables
► Seamless integration of
KYC processes
► KYC due-diligence
documentation in
respective CADD forms for
3,500 customers
► Standard Operating
Procedures (SOP) and
Reporting framework
► Integrated approach to
risk assessment straight
through the transaction
from pre- to post-
acquisition phase
► Weekly Project updates
AML Projects & Experience
Post-merger KYC Remediation | Top Wall-Street Bank
Private & Confidential
Page 17
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Business Issue
► To develop a customized
KYC platform that would
streamline and standardize
the KYC process at the bank.
► The process included client
on-boarding, customer due
diligence (CDD), risk scoring
and KYC refresh
► To incorporate the requisite
aspects of workflow
management, to enable the
bank’s KYC platform to
address specific needs of its
users across geographies,
roles and teams
Region(s)/Countries
► Global
What BMR did
► Acquired an as-is
understanding of paper-
based processes for relevant
to multiple roles and for
teams from different
geographies
► Prepared a Business
Requirement Document
(BRD) for the bank’s
Technology team to design
the platform
► Interacted regularly with the
bank’s Technology team to
develop the KYC platform
► Performed User Acceptance
Testing (UAT) on several
versions of the platform, and
ensure adherence to the KYC
requirements
Key Benefits
► Quicker and more accurate
Client Onboarding
► Effective KYC remediation
mechanism consistent with
local, regional and global
AML/KYC policies of the
bank
► Integrated Risk Assessment
capability in order to:
 Identify the AML risk of
clients
 Arrive at suitable
remediation schedules
based on the Risk
Assessment
► Streamlined Reporting,
especially to Audit and
Compliance
► Supports multi-jurisdictional
rules
► Incorporated customized
form designing consistent
with the bank’s global
standards
Key Deliverables
► Unified KYC platform that
optimized the client on-
boarding process
► Automation of the
complete KYC life-cycle,
from on-boarding to
remediation, including
ongoing diligence, refresh
and an empirical
mechanism to risk rank
the clients
AML Projects & Experience
User requirements & UAT of KYC Platform
Private & Confidential
Page 18
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Business Issue
► Our client was a global top 5
bank who had an extensive
TM setup in London for their
multi-geographic operations
► The bank decided to
transfer this TM setup to
Poland
► This had to be done
seamlessly by aligning the
required processes and case
management from London
Region(s)/Countries
► Regional Hub for EMEA in
UK and Poland
What BMR did
► We assisted the client in
developing SOPS for the
operations specific to Case
Management by:
 Continuously monitoring
suspicious customers
 Developing workflows
 Assessing existing gaps
and potential areas of
non-alignment
 Conducting stakeholder
discussions and feedback
sessions
 Conducting on-ground
assessment of ops
► In addition, we assisted our
client in establishing
effective AML alert
disambiguation processes
using KYC information and
transaction history
Key Benefits
► Seamless transfer of TM ops
to another geography
► Effective Case Management
techniques implemented
► Developed reporting and
escalation structures
► Communication and
reporting lines re-defined
► Timely and accurate alerts
► Consolidation of the
detection process across
multiple channels
Key Deliverables
► Established effective AML
alert disambiguation
processes
► Defined SOPS and
Workflows based on global
best practices and
business requirements
AML Projects & Experience
TM CoE set-up of operations | Top Wall-Street Bank
Private & Confidential
Page 19
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
BMR Value Proposition
Global
Effective
Project Management
Flexible Delivery Mechanism
Thought Leadership
Extensive experience working with global institutions and an understanding and
knowledge of relevant regulations, systems, databases involved in these large-scale,
multi-location projects.
Our team comprises professionals with experience in the Big-Four as well as leading
banks and are based out of India. This One-Global Team has led to significant cost
benefits for our Clients.
We have developed a flexible operational model, that caters to Client needs with
complete data confidentiality/integrity along with effective coordination and project
management. These include on-ground and in-premises models.
High level of engagement of the senior team, with complete focus on problem
definition, solution development and its implementation.
An extensive emphasis on building knowledge of trends, regulations, processes and
technology ensures that the team develops & executes pioneering & best-in-class
engagements for Clients globally.
Value Proposition
Private & Confidential
Page 20
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Sanjay Mehta
Partner & Head of Risk &
Advisory Services
sanjay.mehta@bmradvisors.com
SANJAY MEHTA is a Partner with the firm, leading the Risk and Business Advisory practice. With over 30 years of experience of
advising large Indian and multinational corporations – of which he spent nearly 15 years with Arthur Andersen, and a further 3
years with Ernst & Young. He became a partner in Andersen in 1995, and subsequently became Audit Head and national leader for
the Business Risk Consulting Practice. Sanjay contributed to Andersen’s success by leading several pioneering initiatives in the US,
Europe, Africa and the Middle East. Most Significantly, he led the Telecom practice for Arthur Andersen & EY for the APAC region.
Sanjay is currently the Firm’s leader for Due Diligence assignments, spanning a number of industry sector. His experience in
financial statements, business process reviews, due diligences, performance measurement work, revenue enhancement
techniques, cost reduction and work practices review, reengineering and strategic consulting helps him provide clients with
practical business advice.
Sarabjeet Singh
Partner
Risk & Advisory Services
sarabjeet.singh@bmradvisors.com
SARABJEET SINGH is a Partner in the Risk and Advisory Services practice at BMR and is an expert in the Banking and Financial
Compliances and Utilities Finance Systems, having spent over 9 years working on State Electricity Board clients. Prior to joining
BMR in 2006, he worked for nine years at Arthur Andersen and a further 3 years at Ernst & Young. He has over 21 years’
professional experience, delivering a wide range of services in accounting, due diligence reviews, internal audit, financial reporting
processes, solution development and analytics.
Sarabjeet has also been primarily involved in assurance reviews and audits of large multi-location clients, formulating and
implementing financial accounting packages, policies and practices, operational and financial controls review and financial
systems related fraud investigations. He has extensive experience in AML/KYC matters across geographies and has implemented
global AML/KYC solutions for large financial institutions and multinational banks.
Partner with consulting experience in Anti-Bribery, Anti-Money Laundering & Financial Crimes
Partner and head of Risk Advisory practice with noted leadership Due Diligence & Forensic Services
Risk & Advisory Partners
The BMR Team
Private & Confidential
Page 21
BMR Advisors
Risk & Advisory Services
Anti-Money Laundering
BMR - AML Approach
AML Projects & Experience
The BMR Team
Value Proposition
Contacts
Sarabjeet Singh
Partner
+91 991 034 5454
sarabjeet.singh@bmradvisors.com
Abhishek Bali
Vice President
+91 783 838 3549
abhishek.bali@bmradvisors.com
This presentation has been prepared for clients and firm personnel only. The information contained in this document is for general information purposes only. While the firm endeavors to keep the
information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to
the document or the information provided therein. All information contained in this document may be acquired from publically available sources and hence any reliance you place on such
information is therefore strictly at your own risk and the firm accepts no liability in relation to the use of the document. The firm reserves copyright of this document and hence, does not allow anyone
to sell, re-publish or re-distribute the document or derivatives thereof.
© Copyright 2015, BMR Business Solutions Pvt. Ltd. All Rights Reserved

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BMR Advisors - Anti-Money Laundering Compliance

  • 2. Private & Confidential Page 2 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition BMR Advisors One Microsoft Tax & Advisory Risk & Advisory Mergers & Acquisition Legal Support Deliveredin 40+ countries 7 Locations USA Largestclientbase 3 Centersof Excellence AlliancePartners 40+ Partners Global Delivery Advantage 600+ Employees Experts & experienced consultants 750+ clients engaged Tier 1 Ranked Tier 1 in ITR’s World Tax 2014 guide to the world’s leading tax firms 250+ Fortune 1000 clients served Right-Shoring Choice of on-ground & offshore BMR was founded in 2004 by a group of former Arthur Andersen and EY partners. We are now recognized as one of the top 5 firms in India Chartered Accountants, MBAs, CPAs, ACAMS, ACL Specialists, SAP Specialists, CISA, CCISPL and CFE Ranked as a leading tax law firm by The Legal 500, Asia- Pacific Guide 2013 2+ million hours delivered to date Rated as a Great Place to Work in India Extensive engagements in AML, KYC and Analytics for Global Clients Industry Focus Energy, Financial Services, Retail Technology, Media, Communications, Infrastructure, Real Estate & Japanese Business Group Rated third most active transaction advisor in India by VCCedge League Table for FY2013 40% professionals abovemanager level BMR Advisors
  • 3. Private & Confidential Page 3 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Our Services Risk & Advisory •Process & Performance Improvement •Risk & Control •Due Diligence •Analytics •AML & Financial Compliance Direct Tax •Transfer Pricing •Tax Litigation •Transaction Tax/ Restructuring •Corporate & International Tax •Expatriate Tax •Tax Policy & Advocacy •Tax Outsourcing & Compliance Services Indirect Tax •Advisory •Compliance •Litigation M&A •Corporate Finance •Transaction Support •Transaction Tax/ Restructuring •M&A Legal Legal Support •M&A Support •Direct Tax Litigation •Indirect Tax Litigation •Advocacy •Documentation Japanese Business Group Retail Energy Financial Markets Technology Media Real EstateManufacturing Process Financial Legal Structuring Tax CompetenceServiceLinesIndustry BMR Advisors
  • 4. Private & Confidential Page 4 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Strategic Partnerships & Recognitions Ranked second Most Active Transaction Advisor (Private Equity) by Venture Intelligence League Table for Q1 2011 Rated as a Great Place to Work in India, 2010 Great Place to Work ® Institute Rated Tier 1 Tax Transactional Firm for fifth consecutive year by International Tax Review’s online poll, 2012 BMR ranked sixth (by deal count) in Thomson Reuters Mid-Market Insight, Jan-Sep 2012 Rated third most active transaction advisor by Venture Intelligence League Table for the first half of 2012 BMR Legal Ranked among the top Indian legal tax firms by the Chambers and Partners in the Asia-Pacific Guide 2012 Rated Tier 1 Tax Transactional Firm for sixth consecutive year by International Tax Review’s online poll, 2013 BMR Advisors ranked third leading financial advisor in India for the year 2012 by Thomson Reuters Mid- Market survey BMR Advisors rated as Number One transaction advisor by VC Edge for the year ending 2012 BMR Legal ranked as a leading tax law firm by The Legal 500, Asia- Pacific Guide 2013 Ranked as a Tier 1 Firm in India, International Tax Review, World Tax Survey 2009 2009 2010 2011 2012 2013 Ranked Tier 1 in ITR’s World Tax 2014 guide to the world’s leading tax firms 2014 BMR Alliance Partners 2015 Ranked Tier 2 in ITR’s World Transfer Pricing 2014 guide Most Active transaction advisor for Private Equity and M&A by Venture Intelligence Ranked Tier 1 in ITR’s World Tax 2015 guide to the world’s leading tax firms, 8th year in a row Ranked Tier 2 in ITR’s World Transfer Pricing 2015 guide BMR And Community The firm has a strong commitment to community service. As much as client service, we endeavor to fulfil our social responsibility under the aegis of BMR Foundation. Through our ‘Go Green Initiative’, we adopt environment-friendly practices at our workplace. We actively support initiatives such as SOS Children’s Villages of India, Indian Red Cross Society and MillionTreesGurgaon. BMR Advisors
  • 5. Private & Confidential Page 5 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Our Clients | Financial Services Asset Management AIG Fidelity ING JP Morgan Chase Templeton Banking ABN AMRO Bank AIG American Express Bank Barclays Bank of America BNP Paribas Citigroup Corporation Bank Deutsche Bank HDFC Bank HSBC IDBI Bank ING Bank JP Morgan Chase Ratnakar Bank Royal Bank of Scotland State Street Standard Chartered Sumitomo Mitsui Banking Corporation Templeton Toronto-Dominion Toyota Financial Services Insurance Birla Sun Life Insurance ICICI Prudential ING Vysya PNB MetLife Baer Capital Blackstone Carlyle CVC Englefield Capital GIC Helion Ventures Henderson Halcyon ICICI Ventures IDFC Private Equity India Value Fund Lazard Mandala Capital Motilal Oswal New Vernon NVP Och-Ziff Old Lane Q Investments Sage Shriram Transport Finance Temasek Warburg Pincus Real Estate Funds Actis Aditya Birla Real Estate Fund Ascendas The Chatterjee Group IREO Deutsche Realty Kotak Realty New Vernon Realty Red Fort Capital Solitaire Capital Investment Banks ADM Capital Citigroup Credit Suisse Deutsche Bank Merrill Lynch NM Rothschild Goldman Sachs JPMorgan Lehman Brothers Morgan Stanley UBS Private Equity Alchemy Partners Apollo Investment Corporation BMR Advisors
  • 6. Private & Confidential Page 6 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Our Clients | Non-Financial Services 24/7 Customer ABB Group Accenture Actaris ADM Capital Airtel Airwide solutions Alstom Apple Computers Assa Abloy AstraZeneca Avaya BAF Baker Huges BD BEA Systems BHP Billiton Biocon BlueDart Blue Foods BP Amoco Brightpoint British Gas Broadcom Cadbury Plc. Calleo Canon Cargill CGG Chevron Cisco Systems Claris Lifesciences Limited CNBC Continental Airlines Dabur Daikin EagleBurgmann Enfield Enpro Jubiliant Equant ExxonMobil Fujifilm India General Motors Genpact Goodyear Gujarat Gas GIC GMR Group GSK HDFC Chubb Helmerich & Payne Heidelberg Cements HP Hutch IBM ICA Domus Trust Indigo Airlines Ingersollrand Intel Interglobe Enterprises Itochu Corporation Ivy Comptech K Raheja Corp. Kennametal Widia Kobelco Cranes Kodak Lear Corporation Levi Strauss McKinsey & Co. Metal One Mindtree Consulting Mitsubishi Corp Mitsubishi Material Mosbacher NCR Corporation NDS Nokia Novartis Novo Nordisk Premier Oil Oxigen Panasonic Pepsi Perot Systems Petronas Quest Radhakrishna Reuters Regulatory Data Corp Reliance Industries Ltd Rolex Samsung Sanyo Schlumberger Shell SIA Engineering Socomec Sojitz Sony Star TV Sumitomo Chemicals Sumitomo Corporation Suzuki Synova Tally Teletech Ten Sports Texas Instruments Thomson Uni Products USV Valtech VSNL Xerox Yum! BMR Advisors
  • 7. Private & Confidential Page 7 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Risk & Advisory | Key Services Anti-Money Laundering Anti-Bribery Compliance Intellectual Property Monitoring Risk & Advisory Data Analytics Process Development & Optimisation Internal Audit Process Integration Securitization Support Data Assets Impact Analysis Fraud Investigations Fraud Assessment & Prevention Fraud Analytics Financial & Tax Business Analysis Third Party Ecosystem Risk Management Framework Online, Mobile & New Age Crimes Risk & Advisory Services
  • 8. Private & Confidential Page 8 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Internal Controls Management Oversight Standards Risk Based Framework Remediation & Refinement Transaction Monitoring KYC Due Diligence Training Screening Policy & Procedures AML Technology Support Agent Network Assessment Independent testing AML Diagnostic Check Our Anti-Money Laundering Compliance offerings have been structured to ensure complete coverage of all aspects of the present & emerging compliance challenges. These offerings have been divided into AML Support AML Core AML Investigation Anti-Money Laundering Anti-Money Laundering Compliance Services
  • 9. Private & Confidential Page 9 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Program Management ►Diagnostics ►Risk based framework Operations ►KYC Remediation ►AML Hub ►Process Design & Training ►Threshold Review ►Alert Disambiguation ►Data Analytics Our AML solutions take a modular approach, interfacing with relevant components of the organization’s AML compliance framework BMR - AML Approach The BMR AML Solution Components
  • 10. Private & Confidential Page 10 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Set-up & Operation | Global KYC CoE Business Issue ► To address the identified anti-money laundering compliance deficiencies that affected banks’ business ► To complement the Compliance department’s roll out of its new KYC due diligence process/ Customer Acceptance Forms Region(s)/Countries ► 229 jurisdictions globally What BMR did Determined: ► Unique set of customers for each different business unit ► Existing customer information gaps ► Project schedule and effort estimates ► We developed a ‘One Team Structure’ with multiple personnel ► Successfully managed the entire back-end for 229 jurisdictions and performing customer due diligence for 225,000 corporate customers ► Our operations team performed – background verification, name and news screening, sanction list checking, external research and fulfillment of local country requirements Key Benefits ► Addressed the timelines set by the Regulators for KYC remediation of customers ► A global KYC Repository – for future use ► Quality function introduced in the COE to ensure consistence delivery standards ► Allowed the bank to focus on key AML issues; limit disruption to business; meet the milestones provided by the Regulators ► Educated the team in Mumbai, on KYC documentation and data management Key Deliverables ► Implemented a global KYC Hub – successfully managing the entire back- end KYC processes for 229 jurisdictions ► Developed Standard Operating Procedures, thereby defining clear roles and responsibilities ► Designed IT Solutions for Data Management ► Comprehensive Training Manual for the Operations, developed and training imparted to the all team members ► Developed a Risk and Control Self Assessment (RCSA) for documenting the Risk and Control framework for the COE AML Projects & Experience
  • 11. Private & Confidential Page 11 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Business Issue ► BSA and USA PATRIOT Act: International FATF Recommendations and US legislative regulations mandate a financial institution to conduct appropriate risk-based due diligence on a potential client prior to engaging in a business relationship ► Bank had engaged BMR & Partner Firm to conduct the KYC Remediation of the India domiciled accounts. Region(s)/Countries ► APAC What BMR did ► Identified the customer on the basis of documents, data or information obtained from a reliable and independent source ► Identified, where applicable, the beneficial owner and took risk-based and adequate measures to understand the ownership and control structure of the customer ► Obtained information on the purpose and intended nature of the business relationship ► Identified gaps and recorded requirements in pre-defined templates ► Conducted sales connects ► Management Reporting Key Benefits ► Facilitated the bank to know who they are doing business with in a bid to prevent the bank from inadvertently facilitating money laundering ► Facilitated the compliance to the RBI requirement ► Developed Daily and weekly MIS dashboards, with various information cuts, to report status to management as per their requirement Key Deliverables ► KYC due diligence and gap analysis of over 800 accounts over a period of 6 months ► Sales connects with relationship managers along with status of the connects ► Filtering documents stored on the shared drive to ensure only most updated documents are retained AML Projects & Experience KYC Remediation | APAC operations of a Wall Street Bank
  • 12. Private & Confidential Page 12 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Business Issue ► High volume of monitoring alerts causing difficulties in identification of suspicious transactions ► To expedite the alert disambiguation process, identify false positives and increase review effectiveness Region(s)/Countries ► Americas – NY What BMR did ► We assisted the client in optimizing their automatic transaction monitoring thresholds by: • Identifying anomalies in transaction behavior • Detecting hidden relationships and linked accounts • Identifying beneficial ownership of transactions, and • Analyzing segmental characteristics, based on risk profiling ► In addition, we assisted our client in establishing effective AML alert disambiguation processes using KYC information and customer transaction history Key Benefits ► Reduced false positives ► Timely and accurate alerts ► Identification of suspicious relationships ► Identification of beneficial owners ► Consolidation of the detection process across multiple channels Key Deliverables ► Established effective AML alert disambiguation processes ► Training on alert disambiguation procedures ► Dry runs and implementation of disambiguation processes ► Optimisation of the automatic transaction monitoring thresholds ► Risk profiling of customers AML Projects & Experience Transaction Monitoring Optimization | Wall Street Bank
  • 13. Private & Confidential Page 13 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Business Issue ► BMR was tasked by one of the top 5 global banks to objectively evaluate, independently test and perform an assessment of the bank’s existing AML policies, procedures, systems and internal controls for compliance with relevant AML regulations and regulatory expectations Region(s)/Countries ► Bangladesh, India, Malaysia What BMR did ► A review was conducted both within the context of the compliance regime of the country and international standards. ► As the Bank conducted a high volume of US Dollar denominated transactions and had a subsidiary network outside the country, reviews were conducted in accordance with global guidelines ► Our work included interviews and discussions with key departments and staff members to determine key action areas and solutions with the goal of addressing any AML compliance gaps at the banks. Key Benefits ► BMR independently tested the effectiveness of the bank’s implemented AML program from the strategic policy and operational perspective ► Reported and remediated gaps identified ► Provided more comfort to management on the AML function within the bank Key Deliverables ► Gap report with recommendations for plugging the gapsAML Projects & Experience AML Reviews | CB Partners of global bank post regulator intervention
  • 14. Private & Confidential Page 14 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Business Issue ► To develop a comprehensive PEP database in compliance with Anti-Money Laundering (AML) regulations such as Anti-Bribery Act (ABC), US Foreign Corrupt Practices Act, US Patriot Act etc. ► To enhance the customer due diligence process with the development of the aforesaid comprehensive PEP database Region(s)/Countries ► More than 240 counties What BMR did ► Designed political Structures to holistically capture the PEP definition (global and country specific) ► Risk based Scoring Model to categorize PEPs, their close associates and family members ► Sourced Information pertaining to PEPs from multiple sources such as government bodies, news article, databases etc. ► We performed periodic reviews and assessment of all in-scope countries to keep the developed database updated ► Developed MIS and reporting matrices ► Training manuals and SOP Key Benefits ► Exhaustive database with global coverage of Political Public Figures ► Standardisation of PEP definition, processes across 42 countries, taking into account differing local regulations ► Micro- categorization to distinguish between international, national and local PEPs ► Risk rating to easily view high risk PEPs ► Periodic reviews to maintain countries with current political updates Key Deliverables ► Extensive due diligence report with respect to client’s requirement for 250K+ profiles ► Unified research platform containing complete associations of Political public figures ► Standard Operating Procedures (SOP) and Reporting framework ► Weekly and monthly updates on changes observed in countries political events AML Projects & Experience PEP Review & Build-out | Global PEP repository for 240 countries
  • 15. Private & Confidential Page 15 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Business Issue ► To conduct due diligence based on the global FATF anti-money laundering (AML) requirements and the Wolfsberg Principles for Correspondent Banking for 15K banks ► To create a database for all these set of banks with the required set of documents ► To create an online platform to integrate all the research findings for these banks Region(s)/Countries ► Across multiple geographies globally What BMR did ► We identified and developed a database for sources such as stock exchanges, company registries, news websites etc. (primarily public sources) ► Designed a Correspondent banking due diligence form ► Conducted extensive research and created a database on Correspondent banks that included - ownership structure, management details, regulatory status, correspondent banking certifications ► Developed Standard Operating Procedures and Training manuals Key Benefits ► Robust case management capability with full audit trail and all supporting documentation ► Exhaustive database incorporating data aggregated from multiple sources ► Comprehensive listing of key websites to be screened on a periodic basis for updating information ► KYC due-diligence documentation in respective CADD forms ► Development of an online platform Key Deliverables ► Comprehensive decision- ready reports on banks to provide assurance and protection against anticipated regulatory requirements such as US Patriot Act, FCPA, Anti- Bribery Act, KYC etc ► Standard Operating Procedures (SOP) ► Comprehensive database with set of supporting documents for each bank ► Risk assessment report ► Weekly Project updates AML Projects & Experience Due Diligence | Developing a data set for Correspondent Banks
  • 16. Private & Confidential Page 16 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Business Issue ► To execute integration of processes after a significant Hedge Fund acquisition ► Comply with the US Know- Your-Customer (KYC) regulations regarding on- boarding of customers, in an accelerated manner Region(s)/Countries ► Americas ► Western Europe ► Asia-Pacific What BMR did ► We developed the project plan; communicated and obtained the buy-ins from all locations ► We conducted background checks to identify Senior Public Figures and Politically Exposed Persons and delivered a Customer Risk Matrix summarizing the percentages of customers at different levels of risk ► Our due-diligence specialists conducted the on-boarding due-diligence for 3,500 customers across 7 locations; complied with the US regulatory guidelines and met the project timelines in spite of all the involuntary obstacles Key Benefits ► Access to multi-disciplinary team that provided assistance in process alignment, testing of the Technology platform, due- diligence of customers, project management and reporting on this significant integration effort ► Allowed the bank to focus on key operational and integration issues; limit disruption to business; meet the merger milestones provided to investors ► Educated the teams across 7 locations globally, on due- diligence documentation during a customer on- boarding process Key Deliverables ► Seamless integration of KYC processes ► KYC due-diligence documentation in respective CADD forms for 3,500 customers ► Standard Operating Procedures (SOP) and Reporting framework ► Integrated approach to risk assessment straight through the transaction from pre- to post- acquisition phase ► Weekly Project updates AML Projects & Experience Post-merger KYC Remediation | Top Wall-Street Bank
  • 17. Private & Confidential Page 17 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Business Issue ► To develop a customized KYC platform that would streamline and standardize the KYC process at the bank. ► The process included client on-boarding, customer due diligence (CDD), risk scoring and KYC refresh ► To incorporate the requisite aspects of workflow management, to enable the bank’s KYC platform to address specific needs of its users across geographies, roles and teams Region(s)/Countries ► Global What BMR did ► Acquired an as-is understanding of paper- based processes for relevant to multiple roles and for teams from different geographies ► Prepared a Business Requirement Document (BRD) for the bank’s Technology team to design the platform ► Interacted regularly with the bank’s Technology team to develop the KYC platform ► Performed User Acceptance Testing (UAT) on several versions of the platform, and ensure adherence to the KYC requirements Key Benefits ► Quicker and more accurate Client Onboarding ► Effective KYC remediation mechanism consistent with local, regional and global AML/KYC policies of the bank ► Integrated Risk Assessment capability in order to:  Identify the AML risk of clients  Arrive at suitable remediation schedules based on the Risk Assessment ► Streamlined Reporting, especially to Audit and Compliance ► Supports multi-jurisdictional rules ► Incorporated customized form designing consistent with the bank’s global standards Key Deliverables ► Unified KYC platform that optimized the client on- boarding process ► Automation of the complete KYC life-cycle, from on-boarding to remediation, including ongoing diligence, refresh and an empirical mechanism to risk rank the clients AML Projects & Experience User requirements & UAT of KYC Platform
  • 18. Private & Confidential Page 18 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Business Issue ► Our client was a global top 5 bank who had an extensive TM setup in London for their multi-geographic operations ► The bank decided to transfer this TM setup to Poland ► This had to be done seamlessly by aligning the required processes and case management from London Region(s)/Countries ► Regional Hub for EMEA in UK and Poland What BMR did ► We assisted the client in developing SOPS for the operations specific to Case Management by:  Continuously monitoring suspicious customers  Developing workflows  Assessing existing gaps and potential areas of non-alignment  Conducting stakeholder discussions and feedback sessions  Conducting on-ground assessment of ops ► In addition, we assisted our client in establishing effective AML alert disambiguation processes using KYC information and transaction history Key Benefits ► Seamless transfer of TM ops to another geography ► Effective Case Management techniques implemented ► Developed reporting and escalation structures ► Communication and reporting lines re-defined ► Timely and accurate alerts ► Consolidation of the detection process across multiple channels Key Deliverables ► Established effective AML alert disambiguation processes ► Defined SOPS and Workflows based on global best practices and business requirements AML Projects & Experience TM CoE set-up of operations | Top Wall-Street Bank
  • 19. Private & Confidential Page 19 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition BMR Value Proposition Global Effective Project Management Flexible Delivery Mechanism Thought Leadership Extensive experience working with global institutions and an understanding and knowledge of relevant regulations, systems, databases involved in these large-scale, multi-location projects. Our team comprises professionals with experience in the Big-Four as well as leading banks and are based out of India. This One-Global Team has led to significant cost benefits for our Clients. We have developed a flexible operational model, that caters to Client needs with complete data confidentiality/integrity along with effective coordination and project management. These include on-ground and in-premises models. High level of engagement of the senior team, with complete focus on problem definition, solution development and its implementation. An extensive emphasis on building knowledge of trends, regulations, processes and technology ensures that the team develops & executes pioneering & best-in-class engagements for Clients globally. Value Proposition
  • 20. Private & Confidential Page 20 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Sanjay Mehta Partner & Head of Risk & Advisory Services sanjay.mehta@bmradvisors.com SANJAY MEHTA is a Partner with the firm, leading the Risk and Business Advisory practice. With over 30 years of experience of advising large Indian and multinational corporations – of which he spent nearly 15 years with Arthur Andersen, and a further 3 years with Ernst & Young. He became a partner in Andersen in 1995, and subsequently became Audit Head and national leader for the Business Risk Consulting Practice. Sanjay contributed to Andersen’s success by leading several pioneering initiatives in the US, Europe, Africa and the Middle East. Most Significantly, he led the Telecom practice for Arthur Andersen & EY for the APAC region. Sanjay is currently the Firm’s leader for Due Diligence assignments, spanning a number of industry sector. His experience in financial statements, business process reviews, due diligences, performance measurement work, revenue enhancement techniques, cost reduction and work practices review, reengineering and strategic consulting helps him provide clients with practical business advice. Sarabjeet Singh Partner Risk & Advisory Services sarabjeet.singh@bmradvisors.com SARABJEET SINGH is a Partner in the Risk and Advisory Services practice at BMR and is an expert in the Banking and Financial Compliances and Utilities Finance Systems, having spent over 9 years working on State Electricity Board clients. Prior to joining BMR in 2006, he worked for nine years at Arthur Andersen and a further 3 years at Ernst & Young. He has over 21 years’ professional experience, delivering a wide range of services in accounting, due diligence reviews, internal audit, financial reporting processes, solution development and analytics. Sarabjeet has also been primarily involved in assurance reviews and audits of large multi-location clients, formulating and implementing financial accounting packages, policies and practices, operational and financial controls review and financial systems related fraud investigations. He has extensive experience in AML/KYC matters across geographies and has implemented global AML/KYC solutions for large financial institutions and multinational banks. Partner with consulting experience in Anti-Bribery, Anti-Money Laundering & Financial Crimes Partner and head of Risk Advisory practice with noted leadership Due Diligence & Forensic Services Risk & Advisory Partners The BMR Team
  • 21. Private & Confidential Page 21 BMR Advisors Risk & Advisory Services Anti-Money Laundering BMR - AML Approach AML Projects & Experience The BMR Team Value Proposition Contacts Sarabjeet Singh Partner +91 991 034 5454 sarabjeet.singh@bmradvisors.com Abhishek Bali Vice President +91 783 838 3549 abhishek.bali@bmradvisors.com This presentation has been prepared for clients and firm personnel only. The information contained in this document is for general information purposes only. While the firm endeavors to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the document or the information provided therein. All information contained in this document may be acquired from publically available sources and hence any reliance you place on such information is therefore strictly at your own risk and the firm accepts no liability in relation to the use of the document. The firm reserves copyright of this document and hence, does not allow anyone to sell, re-publish or re-distribute the document or derivatives thereof. © Copyright 2015, BMR Business Solutions Pvt. Ltd. All Rights Reserved