Introduction
KPMG has extensive experience in assisting professionals on their Forensic and AML/CTF journeys, helping them turn compliance from an exhausting burden into a seamless process. Our solutions can give you a competitive edge, enabling greater program agility, effectiveness, efficiency, sustainability, and integration. KPMG also brings its expertise to the forefront in crisis management, investigating allegations or suspicions of misconduct and delivering value by helping to understand facts, gather evidence, and recover losses.
Our Know Your Business Relationships (KYBR) service is a one-stop, comprehensive solution that enables you to fulfil your AML/CFT due diligence obligations effortlessly for all your business relationships. Additionally, it can facilitate effective risk mitigation against money laundering, terrorist financing, and sanctionable threats.
Common challenges
Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) remain high on professionals’ agendas. As the regulatory landscape is continuously adapting to developments in different areas (finance, technology, cryptocurrency, cyber/environmental crime, international sanctions, fraud, bribery and corruption, and geopolitics), AML/CTF governance frameworks and corporate integrity are continually in the spotlight. Failure to comply can result in massive regulatory fines (up to millions of euros), not to mention the reputational damage that comes with it.
The challenges associated with AML and CTF include:
- Regulatory change management
- Modernizing AML / CTF programs through data & technology infrastructure
- Maintaining efficient, reliable, and sustainable AML/CTF practices
- Adapting to developments in cybercrime, the use of cryptocurrencies and virtual assets
- Allegations or suspicions of misconduct such as fraud or bribery and corruption
- Maintaining compliance programs to ensure that potential misconduct is detected, reported and investigated properly and in a timely manner
How solid is your AML/CFT control framework?
The AML/CFT regulatory landscape is continuously evolving. Competent authorities expect to see a strong and robust AML/CFT control framework in place and an efficiently performed AML/CFT due diligence on all your business relationships. Are you, as a compliance function, conducting officer, RR (Responsable du Respect) or RC (Responsable du Contrôle):
- Feeling overwhelmed with the increasing AML/CFT obligations?
- Having a growing backlog of due diligence files to review?
- Experiencing inconsistencies in the application of your due diligence framework?
- Looking for a cost-effective and technology-driven solution that reduces turnaround time?
- Lacking AML/CFT expertise or resources in-house?
- Struggling to meet your deadlines of initial and ongoing due diligence cycles?
- Noticing delays in finalizing the due diligence reports of your business relationships?
If the answer to at least one of the above questions is “Yes”, you may be exposed to money laundering, terrorism financing and sanction threats.
To help you limit that exposure, we have created the Know Your Business Relationships solution – a managed service provided by our AML/CFT experts, facilitated by a web-based tool.
Our solutions
KPMG helps you identify and assess risks and conduct investigations, remediation and operational transformations related to a wide range of financial crime issues relevant to anti-money laundering, sanctions, fraud, bribery and corruption, counter terrorism financing and tax evasion. We design and implement new operating models, help prevent the reoccurrence of previous problems, perform test controls, and transform the culture and capability of the organization.
We work with professionals from the banking, asset management, insurance and real estate sectors who must fulfil the same AML/CTF legal requirements but have somewhat different challenges and market practices. KPMG also works with highly skilled professionals in the corporate and public sectors: they face different challenges that need to be properly understood to be addressed.
Sector Specific Solutions
Banking, Asset Management, Insurance, Real Estate, Industry, Services, Public Sector
Proactive and Risk Assessment
Tailor-made solutions to address specific needs
Advanced Technology-based Tools
Forward-looking & expert-led automated tools
Up-to-date-Regulatory Expertise
Our professionals operate globally, drawing on a huge network of expertise
Crisis Management
Advanced investigation services, using technology and human expertise
Detailed services
Risk Assessment Solutions
Client challenges
- Targeting individual risk factors (customer, geography, product, services and transactions, delivery channel)
- Customer due diligence obligations
- Designing effective policies which accurately identify and assess risks relevant to the professional
- Increased regulatory scrutiny
Our solutions
- Design and implement a risk-based approach
- AML/CTF Risk Navigator Tool
- AML/CTF Maturity Assessment
- Country Risk Assessment
Review and/or design AML / CTF Framework
Client challenges
- Designing frameworks which address emerging and multifaceted threats
- Keeping the policies and procedures up to date
- Time and labour-intensive processes
- Reactive rather than proactive procedures
Our solutions
- In-depth framework review & gap analysis
- Assistance in defining a risk appetite
- Review and update of policies and procedures
- Process validation and/or redesign
- Assistance with AML/CTF/KYC tool selection and/or implementation
- Regulatory Watch
Remediation Services
Client challenges
- Backlog of KYC files
- Legacy portfolio of customers
- Large volume of periodic reviews
- Regulator-driven remediation
Our solutions
- Implement and conduct an AML remediation plan and program
- Assist and support the compliance function in addressing any specific AML/CTF matters or needs
- Project management
Training
Client challenges
- Staying up to date on roles & responsibilities of professionals
- Ensuring employees are knowledgeable on AML/CTF/Sanctions
- Meeting regulatory obligations
- Adapting trainings to the different staff audiences
Our solutions
- Help design training programs
- Tailored training sessions, from refresher courses to more detailed training workshops
- Delivered by experts from the field using real-life examples
- Face-to-face and E-Learning formats
- Updates on regulatory developments
Transaction Monitoring
Client challenges
- Heightened expectations from regulators
- Inefficient systems resulting in the production of large volumes of alerts
- Current alert review processes frequently relying on extensive teams of personnel, often spread over disparate geographical locations
- Scenarios not detecting real risks
Our solutions
- Assistance in fine-tuning your TM tool
- Assistance in scenarios definition
- Ad hoc assistance with alert clearance
- Management information and analytics
Sanctions Management
Client challenges
- Increasing and evolving regulations and legislation which create a complex regulatory environment to operate in and comply with
- Existing sanctions screening systems which often result in the production of large volumes of false positive alerts
- Limitations of poor systems tuning and regulatory change in which create alert spikes and backlogs in many institutions
Our solutions
- Design and implement sanctions policies and procedures
- Assess procedures as well as sanctions screening systems
- Efficiency testing
- Ad hoc assistance with alert clearance
- KPMG Sanctions Alert Classifier
- Sanctions screening testing platform
Fraud / Bribery and Corruption Management
Client challenges
- Complex and international regulatory landscape
- Reporting canals (whistleblowing lines)
- Complex scenarios involving the knowledge of fraud and corruption schemes and risks
- Integration of fraud and corruption risks into governance models
- Cultural aspects
Our solutions
- Fraud and corruption risk assessment
- Design and implementation of anti-fraud and anti-corruption programs
- Full design and implementation of whistleblowing lines, including the case management of the reports
- Governance model review and assessment
- Design and implementation of governance models considering specific risks and cultural aspects
Investigation services
Client challenges
- Financial losses, reputational risk, impact on teams in case of misconduct
- Defining a strategy regarding the investigation outcome (disciplinary measures, jurisdictions)
- Gathering documented facts in order to take action
- Defining the root causes of the issue in terms of governance, processes, internal controls, corporate culture
- Large volumes of data to review with the right methodology
Our solutions
- Assisting in defining the strategy
- End-to-end investigation process, from interview of whistleblowers to fact-finding report
- Forensic interviews
- Forensic technology: computer forensics, forensic data analytics, eDiscovery
- Remediation plan and lessons learned
Forensic Technology
Client challenges
- Locate, collect, process, and produce large volumes of data as part of investigations, litigations and disputes or regulators requests
- Variety of hard supports to collect data (laptops, mobile phones, tablets…)
- Chain of custody (is the data produced acceptable for the relevant jurisdictions?)
- Gather relevant and hidden information (deleted files, protected files)
- Make sense of large volume of data
- Review of unstructured data (pdf, photos, sound, video, chats…)
Our solutions
- Assisting in defining the review strategy
- End-to-end eDiscovery process: collection, processing and production of data
- Technology-assisted review, machine learning, saving thousands of hours of review
- State-of-the-art review platforms, depending on the size and complexity of the review
- In-depth forensic analytics
RC support services (Responsable du contrôle)
Client challenges
- Appointing a “Responsable du contrôle du respect des obligations” (RC) to comply with Luxembourg’s AML/CTF requirements
- Tracking and adhering to new and updated rules and industry standards to fulfill CSSF Regulation No. 12-02 rules
- Preparing and delivering training content in line with regulatory requirements
- Ensuring collected data is accurate and complete
- Overseeing AML tasks delegated to transfer agents, distributors or portfolio managers
- Tackling unexpected workloads, regulatory inspections and resource constraints
Our solutions
- Create, monitor and update AML/CTF policies to reflect changes and recommendations
- Draft, complete and update risk appetite documents, compliance monitoring plans, annual summary reports and financial crime questionnaires
- Complete Financial Intelligence Unit (FUI) goAML tasks
- Create reports for management and board of directors
- Liaise with authorities regarding documentation requests and surveys
- Perform due diligence, ongoing screening and transaction monitoring
- Ensure investors, distributors and assets are given the correct risk score
- Assist in completing the Questionnaire on Financial Crime
- Implement, track and execute AML remediation plans
- Prepare and deliver training content in line with regulatory requirements (In-person or eLearning platforms
Want to know more?
The future demands a collaborative approach that sustains a sharp lens on both internal and external factors impacting your business and the world beyond it.
—KPMG Global
Know your business relationships (KYBR)
KYBR is the ultimate one-stop solution to meet your AML/CFT due diligence obligations for all your business relationships, such as customers, investors, assets, transfer agents, portfolio managers, custodians, brokers, distributors, and more.
How we can support your KYBR journey
Whether you are a management company, bank, investment fund, asset service provider, payment institution, PFS, insurance company, or in any other profession, we understand your AML/CFT challenges and commit to working with you to achieve the desired outcomes. This can be accomplished thanks to our years of proven, international, AML/CFT in-hand expertise, innovative technology-based solutions, tailored approach, focus on high-quality deliverables and strict data security standards.
In a nutshell, KPMG’s Know Your Business Relationships is composed of two key elements:
- A web-based tool, combining workflow and case management with a data and information repository, designed to effectively assist your organization in meeting its AML/CFT due diligence obligations. It has been developed to address the specific needs of the Luxembourg market, and is suitable for all types of relationships, such as: customers, investors, assets, transfer agents, portfolio managers, custodians, brokers, and distributors.
- A dedicated team of AML/CFT experts, who perform the first-level due diligence review-collect and review the documents and information according to client type and risk level, perform the screening, and prepare the file for your final validation.
What’s in it for you?
Due diligence on all business relationships
- Fully customizable Due Diligence controls on all your business relationships (such as Assets, Distributors, Depository Bank, Investors, Custodians, Customers, etc.), in line with the applicable lay and regulations and market practice.
Single Repository & Dashboard tool
- Efficiently store and manage Initial and ongoing Due Diligence assessments and documentation on all your business relationships in one place
- Overall view and quick access to the Due Diligence files and statuses via Dashboard
- Minimized Compliance risk
- Audit trail
- Always availability to view and download documentation
KPMG Support service
- Liaising with your counterparties to retreive the required Due Diligence documentation
- Initial & Ongoing AML/CTF Due Diligence on all your business relationships, according to the type of relationship and risk level
- Identification of potential risk factors
- Centralized assessment of screening alerts
- Retention of data as per Data Retention Policy
- Tracking Due Diligence status for periodic Due Diligence cycles
- Clients are required to focus only on final approval of the Due Diligence assessments, performed by KPMG
Access to AML/CFT & regulatory experts
- Due Diligence reviewed by industry experts
- AML/CTF and regulatory expertise available on demand for specific cases
- Good understanding of regulator's expectations
KPMG Integrity Line
Our Integrity Line is an end-to-end solution that implements a whistleblowing policy and line, performs triage of reports, and investigates them accordingly.
- Organizations must comply with the transposition of EU Directive 2019/1937 and implement a whistleblowing line to allow employees and third parties to report potential breaches of EU and Luxembourg laws
- These organizations must design policies, build a framework to receive reports and perform triage to be able to address only the relevant reports
- Organizations will have to be able to investigate all serious reports and respond to whistleblowers in a timely manner, or else risk non-relevant reports to go public or directly to the authorities
KPMG Integrity Line is an end-to-end solution which can be tailored to each need, from the design of the policies to platform implementation, case management of reports, and the investigation of relevant cases.
- Design of policies
- Whistleblowing platform implementation
- Communication and training
- Case management
- Response
KPMG and the EQS Group have been working together to offer customers an integrated compliance solution in whistleblower systems and have done so successfully for years in neighboring countries such as France, Germany and Belgium.
