Turning global regulation into workable processes, systems and behaviour
Client
An international financial institution
Role
Setting up governance, project planning, process design and training
Financial institutions increasingly deal with legislation on providing information and personal data. Governments use those frameworks to counter tax evasion. The OECD Common Reporting Standard is a major step towards a globally coordinated approach to exchanging financial account information between tax authorities.
CRS requires financial institutions to identify clients according to CRS requirements, verify in which country they are tax liable, and report information on foreign tax residents to the local tax authority. That touches the full client journey, from onboarding new clients to changes in client data such as residence or contact details.
Without global reach, individuals or organisations could route investments through other countries and avoid local tax authorities. The regulation builds on earlier frameworks such as FATCA and the European Savings Directive, and requires a coherent translation to the bank's practice.
We set up the governance structure and project team, delivered a project plan, organised resource deployment and secured the necessary budgets. That gave the trajectory a clear frame in which choices could be made and followed up.
On that basis we designed the procedures and supporting systems, including testing, for onboarding new clients, opening new accounts and processing changes in client data. Training and instructions for all involved employees were an integral part of delivery, so that the new way of working also became workable in daily practice.
The difference emerged when procedures, systems and behaviour were designed in coherence. The bank could report accurately to the local authority because the processes around client intake and data changes were aligned to it, and because the employees working with it knew why and how.
An international regulatory change thus became not a standalone compliance exercise, but an organisation-wide movement that made the way of working more consistent across the entire client chain.
Global regulation rarely touches one department. It touches processes, systems, governance and the people working with them. Those who tackle that in coherence get compliance that works, and an organisation that has designed itself better to deal with future regulatory change.
Workable work in a heavily regulated context is exactly that: clear procedures, supporting systems and well-prepared people, so regulation becomes not a brake but a trigger for better organising.
