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Reassessment of real estate bank files with today's knowledge
Based on a project we did at a real estate bank, this article aims to give you more insight into our CDD project approach and what you can expect from us.
Tightening of laws and regulations as a trigger
Because of the tightening of anti-money laundering regulations concerning CDD, the real estate bank wanted to reassess existing files. The bank itself had already updated its guidelines for assessing new clients.
Reassessing CDD files
The bank has requested us to reassess about 1,200 existing CDD files of its commercial real estate clients. Previously, the interpretation of the laws and regulations indicated that it was sufficient to disclose the origin of the source of wealth. Today’s knowledge proves that evidence is also necessary. Therefore, our reassessment focused on substantiating the source of funds/wealth and the released liquidity destination.
We did more than just repairing files. With our substantive knowledge and experience, we were able to optimize existing CDD procedures and work instructions. In this way, we offered real added value for the client.
A multidisciplinary team and setting the bar together
As our clients could expect from us, we deployed a well-attuned project team on this project. A multidisciplinary team with junior, medior, and senior CDD analysts, finance specialists, and a project manager. The project manager was the client’s permanent point of contact, who knew the bank well and communicated directly with the account manager at Partner in Compliance. As with any project, especially at the beginning, we set the bar for the reassessed files’ desired quality together.
The start of the reassessment was the mapping, by our finance specialists, of the originally contributed funds. Based on this, our CDD analysts could supplement the files further, conduct research, and write the analyses, resulting in the required risk category recommendations. Our senior CDD analysts then performed a 100% check.
The final responsibility for CDD files always lies with the client. Therefore, the bank’s operations manager carried out a second check. However, for complex cases, the bank’s CDD committee made the final decision regarding the proposed risk classification. Their feedback addressed to our project team contributed to the team’s commitment. It is, and always will be, a matter of cooperation.
The result: files in order, adjusted CDD instructions, and a satisfied client
We determined the required risk classification for all the files we reviewed. If the source of funds/wealth could not be explained or when a client did not want to provide information, the recommendation was to discontinue services or exit the client. During the project, we adapted and rewrote the existing CDD procedures and work instructions. In this way, we were able to use our knowledge and experience optimally for the bank.
The bank was very satisfied with our best practice approach, the delivered quality, and the achieved results. In particular, the bank positively valued our pragmatic approach with an eye for the client’s business operations, listening to employees, continuous advice and interim coordination of the file structure.
Would you like to know how we can support your organization in the field of CDD? Please don’t hesitate to contact us.
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