The Foreign Accounting Tax Compliance Act was rearing it’s head and although the regulations were in draft phase, due to it’s size and impact on all financial institutions, many banks took a proactive approach to start analysing the regulations. The challenge here was to interpret what the regulations required and what Barclays Bank needed to implement within their client onboarding processes, knowing that it was a moving target until the regulations were made final.
We were brought in to work with the KPMG legal team and BCS Consulting to interpret the regulations into a draft policy that covered both Barclays Investment plus Barclays Corporate arms of the business. As well as this, we worked towards designing and building a compliant customer journey for their investment and corporate clients.
With over 500 pages of text, we spent 2 weeks in a “war room” to read through the regulations and interpret each paragraph in a way that made sense to both the business and technology teams.
We worked closely with the KPMG legal team to make sure that our translations of what the regulations were stipulating were correct and subsequently started to translate these into a FATCA onboarding policy for Barclays, creating a set of regulatory requirements first before developing a clear list of what Barclays needed to do.
We developed a FATCA regulatory requirements matrix that covered the entire scope of the regulations, enabling traceability to be easily documented from the regulations all the way through to each piece of functionality that would need to be built into the customer journey and onboarding process to meet it.
The Standard Operating Procedures (SOPs) had not been updated for years, so we took the time to sit with each team and understand what each person did as part of their role.
We created a visual diagram that showed all the tasks from the point a client contacted Barclays to the point of opening their first accounts for the investment banking division and highlighted all the areas within the customer journey that would require some form of change to become compliant with the regulations.
It was important that we captured the onboarding processes across all global teams and standardise them as much as possible so that everyone was following the same process.
Gap analysis is the process of identifying the differences between where you are now and where you want to be.
With today’s processes all drawn out, we highlighted where the onboarding process needed to be changed, what data it was and wasn’t capturing based on the regulatory requirements and more importantly and where a manual task could potentially be automated.
FATCA requires a client to be assigned to one of the many FATCA classifications, so it was important that the criteria to classify was fully met when capturing data when onboarding a client to make that determination.
Regulations are un-necessarily complicated. An important part of what we do at 5S Projects is to break everything, including regulations, down into simple terms so that the action steps on a business to become compliant are clearly understood.
We conducted sessions to educate all stakeholders in parallel to making the required system changes in customer journey and onboarding processes, translating a hard to follow regulation into a simple list of requirements for technology to build from.
Working across investment banking and corporate divisions really helped to create a unified approach and policy for the bank, with the KPMG legal team confirming accuracy of our translations.
Not only did it bring the two areas closer together, but it helped to bring Barclays into compliance operationally in a collaborative and streamlined way ahead of the finalised go live date for FATCA.
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