Even though there are no regulatory pressures on companies
when it comes to on-boarding business to business (B2B) relationships,
companies are ever more concerned on aspects that might ruin their reputation
or link them with any organisation that proves to be associated with negative
media. This is leading to increased due diligence checks on suppliers,
affiliates, agents, operators or any other kind of business relationship. This
is mitigated through rigorous due diligence processes including specific
documentation, questionnaires / forms as well as calculation of the associated
risk. All of this bring the same operational challenges of dealing with such
processes as any regulated industry. The problem of never-ending communication
on email, checking of documents, assessing of risk and many other steps before
such a business relationship can start.
This approach applies to many industries such as the
pharmaceutical industries, engineering, telecommunications and aviation.
However, one industry that is also taking this quite seriously is the gaming
industry. Already operating in a high-risk environment due to the AML aspects
on players, gaming operators are on the front line of also reducing their risk
when getting into business relationships with other corporates.
This global gaming operator has opted for the deployment of
KYC Portal as the underlying structure of the entire B2B on-boarding process and opted for integrated with GBG for further automation, the project is aimed at
streamlining the entire process and reducing the amount of manual effort
required in approving (or not) a business relationship.
The entire project is made up of the following main
components described in more detail below.
- Configuration
and setup of KYC Portal
The project started with the definition of
what is required from the corporates at on-boarding and ongoing stages. Our
client focused on creating a programme for the on-boarding of Suppliers,
Affiliates, Operators and White Label relationships. All of these require
thorough due diligence on the corporates being on-boarded. KYC Portal has been
set up in a way were each programme has a separate configuration. The
programmes focused on creating the requirements of data collection, fields,
questionnaires, risk scoring and workflows based on the service that the
corporate is being on-boarded for. This allows the system to be able to assess
and move the respective applications based on the requirements defined.
- Giving
corporates access to the Customer Outreach Tool for self on-boarding
The customer facing plugin of KYC Portal
called the Customer Outreach Tool (COT) is what is presented to the external
corporates. The look and feel of this interface has been changed to be in line
with the visual requirements of the gaming operator. Changing the colour
schemes, fonts and logos to match the identity of our client.
Once a corporate is about to be on-boarded,
they are given access to COT to be able to setup their own account securely.
COT presents all the workflow of on-boarding to the end customer in a simple
guided 4 stepped KYC process. Which interface is dynamically built using the
configuration in step 1 above. The user is first guided into populating the
form requirements based on the respective settings of the programme. This
dynamic approach of defining the fields that appear within COT allows the
compliance team to update the data set at any point in time based on regulatory
changes and internal policy. The next step in the process is that of uploading
the required documentation, which list is also dynamically built using the
configuration that the compliance team set in the first place. Any
questionnaires that are required such as the declaration forms, source of
wealth and source of funds are presented to the client in the third step.
Finally, in the fourth step, the client can start adding the involved parties
within the structure allowing them to build the entire hierarchy of their
company. Throughout this process the customer can easily communicate with the
organisation using the inbuilt chat function, as well as conducting audio and
video calls. Such communication is fully audited against the application as
well as being able to playback any of the recordings at any point in time
Once all is ready within the application
the customer can submit the entire application which in turn notifies the
on-boarding team.
- Backoffice
on-boarding process in KYC Portal
Once the application is received, the
compliance team can see the entire application that has been submitted with the
entire company structure, all the data for each party, uploaded documents and
filled in questionnaires. By the time the application has been submitted, KYC
Portal would have already calculated the risk on the entire application as well
as the risk per entity involved in the structure.
The second that an application is submitted
in KYC Portal, all the entities (both legal entity as well as individuals) are
automatically submitted for a screening check. This client chose to integrate
KYC Portal with the services of GBG. The automated service submits the subjects
for on-going monitoring, meaning that should any subject appear on a PEP list, Sanction
list or should any adverse media result in a match, then KYC Portal will notify
the compliance team daily (only if a potential match is found). Agents can then
act accordingly based on the results being returned.
Also, this operator integrated the services
of GBG when it comes to the Enhanced Due Diligence process. The compliance team
opted for a manual trigger, whereby they decide on which subject they require a
more thorough investigation. Once this trigger is set (a status button which
they configured within KYC Portal), the system adds this request to a queue
which is sent to the system of GBG automatically. Once GBG finalises the report
and submits it to KYCP, the latter will file the PDF version of the Enhanced
Due Diligence report against the subject in the document panel in KYC Portal.
The compliance team is automatically informed that the report has been
finalised so that they can resume with the process of evaluating the
application.
- Ongoing due
diligence process in KYC Portal
On all corporates on-boarded in the past, KYC
Portal will then alert the team on the ongoing obligations of KYC and AML.
Based on the review policy settings that compliance would have set at programme
level and based on the real time risk perception, KYC Portal alerts the
compliance team when the respective review is due. The compliance team will
then access the respective application / corporate and trigger the request for
whatever material needs review (such as updating of details, confirmation of
data, new documents, etc). This will trigger a notification to the customer to
access their account within the Customer Outreach Tool. Once logged in the user
will be able to see the specific tasks that are required for the review process
as well as allow them to go through all the requirements in one, central,
audited platform.
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KYC
Portal is all about streamlining the back-office operations of KYC and due
diligence, not only at on-boarding stage but also throughout the entire
lifetime of a subject. Use cases like the on above help the market in
understanding what benefit can be achieved through automation of processes.
Automation that not only reduces the cost of such processes, but also reduces
the risk exposure that one is on-boarding within their business.