THE CHALLENGE

The client’s engagement with the Axis Corporate team focused primarily on the following activities:

• Identifying and extracting the regulations that are applicable to the business model of the target country being analysed, and their impact on the client/product relationship.
• Conducting an in-depth, exhaustive analysis and review of local and community regulations, which covered the full range starting with European directives and finishing with local regulations.
• Diagnosing and identifying regulatory and operational gaps in the set of policies, procedures and generally all the internal documentation upon which the operation of the new branch is based.
• Defining the objective operational model that includes a detailed description of the roles and responsibilities, the organisation, the systems to be used and the (Key Performance Indicators/Key Results Indicators)  that are to be used for monitoring the results
• Designing an operational action plan with a road map for addressing the Regulatory Gaps detected in order of priority.

HOW WE HELPED

Our proposal was based on the design of a service model for regulatory certification, which would provide support to the process of opening a new branch.

The project consisted of the following elements:

A diagnosis of the situation, with a surveying and analysis of the level of compliance regarding the requirements of Regulatory Compliance, of the policies, practices and organisational structure and Governance that the entity had designed and configured for the opening of the new branch. This phase included the analysis of compliance with the Anti-Money Laundering (AML) 4th Directive and the requirements of the Foreign Account Tax Compliance Act (FATCA)  and Common Reporting Standard (CRS) regulations, among others.

In this phase, special attention was centred on the issues where the local regulation differed from or was more demanding than the European regulation, with a greater increase in the depth and detail level of the diagnosis.

Functional redesign and support for the operationalisation of the resulting procedures based on the Regulatory Gap detected.

After the analysis that was carried out, Axis created plans to implement the solutions and updates necessary to comply with the regulatory environment of the new branch, obtaining the models and procedures necessary to that end, together with an operationalisation plan to validate the regulatory compliance of the new branch.

The analysis and redesign work required significant coordination work with various stakeholders involved in the process, which included Legal Advice, Regulatory Compliance, Product, Tax Advice, Systems, Banking Services and Internal Audit. This entailed a sophisticated engagement process in managing the interactions and inter-departmental dialogue between the various levels of such a large group.

RESULTS

• Success in the complex process of requesting permission for the opening of the new branch from the relevant regulators. This process was approved and validated for its adaptation to the “Banking Passporting Rights” of the country where the new branch is based.
• Obtaining the regulatory certification that involved the implementation and adaptation of internal documentation (policies, procedures, etc.) to the various relevant laws, norms and regulations in the chosen European financial market.
• Designing a pilot documentary framework to achieve efficiencies and use lessons learned from the initial project for future openings and restructuring.