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Financial Crime Compliance
It is no longer sufficient to ‘go it alone’ Forensic
02
Financial Crime Compliance
The issue at hand
Negative publicity, damage to corporate
reputation and loss of goodwill, legal and
regulatory sanctions and adverse effect
on the bottom line – are all possible
consequences of an organization’s
failure to manage the risk of financial
crime. With regulators adopting stricter
regulations on financial transactions
and enhancing their enforcement
efforts, institutions are facing increased
complexities in being compliant.
With penalties for non-compliance
only getting steeper, what financial
institutions need to focus on today
are not only the costs that need to be
incurred on remedial measures but
also improve processes and operational
controls to help mitigate these risks in
the future.
Financial services
organizations are
struggling to manage
and control elements of
financial crime.
The threat of financial
crime runs the gamut
of financial fraud and
abuse, such as money
laundering, bribery
and cybercrime. It has
therefore become too
broad to be handled by
established divisions or
departments.
An enterprise-wide
approach is essential
and should leverage
new analytical
software tools.
The Financial crime lifecycle
Monitoring and testing: Assessing
financial crime systems and policies to
ensure they are efficient and talloring
systems to meet changing internal and
external threats.
Compliance: Acting in accordance
with the requirements of relevant
authorities by implementing
governance structures and financial
crime strategies.
Investigation and remediation: Assessing
allegations of fraud or financial mismanagement,
responding to government regulatory requests,
and helping financial services organizations
remedy issues and prevent their recurrence.
This invoices data assessment, e-discovery,
understanding relevant laws and regulations, and
undertaking cyber response activities.
Prevention and detection: Reducing financial
crime incidents and identifying early issues and
risks by implementing effective operational controls.
The focus is on enterprise fraud and misuse
management using integrat4d technology platforms
and advanced analytic.
"Just because your bank's
compliance challenges are
unique does not mean you
must tackle them alone"
03
Financial Crime Compliance
What we can do for you
Regulatory compliance | Anti-money laundering (AML) services
Developing or enhancing
your AML framework and/ or
target operating model based
on regulatory requirements
and leading industry practices
We have advised several financial institutions including global financial institutions in
enhancing their AML framework and/ or target operating model. This includes undertaking
gap analysis vis. a vis. local regulatory requirements, their global AML polices/ procedures
and benchmarking them against industry practices.
AML training for employees
to facilitate knowledge and
capability building
We have helped conduct AML awareness/ training workshops for senior as well as middle
management. This entails a comprehensive program tailored to every organization’s culture
and product base to train and create awareness amongst staff on key AML issues.
AML due diligence We have helped clients in getting clarity on the target’s business profile; KYC procedures;
existing systems and controls; and overall compliance with AML legislation as part of a pre-
acquisition review of the target’s AML systems and controls.
Assist in transaction look
back exercise
We have assisted clients in undertaking a review of historical transactional data with respect
to sanction screening and reporting of SARs (suspicious activity reports).
Implementation or
enhancement of your
transaction monitoring
system
We have assisted Global and Indian clients in enhancing their transaction monitoring systems;
including reducing false positives, enhancing/ developing the alert clearing process as well as
quality assurance of their alert clearance process.
Client on-boarding and
remediation programs
We have assisted clients in India as well as globally with planning and implementing account
remediation/ periodic refresh exercises using an offshore model with inbuilt quality
assurance processes and tools to manage this process effectively.
AML Investigation We have undertaken some of the largest AML investigations in the country. We also have
experience of having undertaken investigations on behalf of regulators for some of the
largest financial institutions in the country.
The International Monetary Fund estimates the amount of money laundered globally in one year is between 2 to 5% of the global
gross domestic product (GDP).
04
Financial Crime Compliance
Financial services: Banking
Fraud risk management - We have helped several financial institutions in undertaking a review of their
portfolio and enhance their fraud risk framework. The team has experience of undertaking work in retail and
commercial asset portfolios and cybercrime risk.
Forensic audit - We have assisted regulators in undertaking a review of non-performing assets (NPAs)
declared by the Bank and under-reporting, if any. This included determining the actual value of NPAs,
reviewing the systems and its deficiency, top management involvement, if any.
Investigation - We have assisted Banks, Regulators and the Ministry of Finance in undertaking various
investigations into allegations regarding employees including top management and determining process
weaknesses leading to the incident.
Stressed asset management - We have worked with a number of Banks and consortium of banks in
undertaking a forensic review of the stressed asset portfolio to identify misuse of facilities granted by the
bank including diversion/ siphoning of funds. We have undertaken more than 20 forensic audits which
included three entities that were part of the top ten NPA accounts in India.
Forensic data analytics/ Early warning system - Based on our experience of working with other financial
institutions, our tools have been customized to identify patterns, nonobvious relationship identification and
inductive analysis techniques to analyze your customer and transactional data which can identify potential
outliers in the data, helping identify fraud risks sooner than later.
05
Financial Crime Compliance
Financial services: Insurance
Enhancement of fraud risk management
framework - We have helped several
life and non-life insurance companies in
undertaking an independent assessment
of their processes, identified gaps and
recommended measures to enhance
their fraud risk framework. The team has
extensive experience of working across the
entire insurance value chain from customer
acquisition to policy management and service
to claims management. We also support by
carrying out strategic interventions wherever
required so as to enhance the existing fraud
management framework in their companies –
by preparing an anti-fraud policy, by training
their resources, by recommending and
supporting implementation of a governance
structure and framework.
Claims management - We have
worked with a large number of
insurance companies – especially
on the non-life insurance side – in
developing a fraud analytics solution
for the claims management space.
The solution involves setting up
of customizable business rules for
the client which then enables the
company to identify high risk claims
at the claims notification stage
itself and undertake enhanced due
diligence measures for such claims.
Customized investigation
procedures - We have carried out
claims investigation engagements in
cases which are of sensitive nature
or involve high claims pay-out.
These type of investigations involve
carrying out market intelligence
procedures to identify if these are
instances of fraudulent claims.
We have supported insurance
companies in carrying out mystery
shopping exercises to check the
efficacy and effectiveness of their
anti-fraud controls. This has been
across multiple areas including sales,
distribution, customer service and
claims.
Insider Trading - We have also
worked with a few companies across
different sectors to investigate
into allegations of insider trading
made against senior management
personnel.
Setting up of fraud control units - Since
the fraud management space in the Indian
insurance industry is still evolving, we also
help insurance companies set up their
fraud control units – by putting in policies,
procedures in place as well as loan staffing.
Investigation of market abuse cases -
We are the only Big 4 in India to have
investigated all the high profile market
abuse cases that have taken place
across different types of capital market
entities – asset management companies,
brokerages, etc. These cases have also
involved us working in close conjunction
with the regulator.
01
02
03
04
05
06
06
Financial Crime Compliance
Select relevant forensic credentials in the financial sector
We have worked with multinational and domestic banks in the private and public sector, regulatory bodies and the government
institutions to ensure enhancement of anti-fraud frameworks and financial crime compliance.
Assisted a large global bank with
reviewing and remediating more than
65,000 client files across multiple line
of businesses to comply with revised
standards of the Bank on a managed
services model.
Assisted a multinational bank with
AML/KYC policy and procedures gap
analysis subsequent to a revised
AML global standards roll out. The
engagement also included assisting
the bank with reviewing and KYC
upliftment for high and medium risk
customer files for its India operations.
Undertook forensic audit on more
than 20 financial institutions to assess
the quantum of loss to the banking
system by a borrower.
Conducted a detailed forensic review
into money laundering allegations
raised during a sting operation.
Assisted a global bank in review of
its Offshore Banking Business in light
of heightened global issues around
offshore banking. This included review
of their AML framework and sample
KYC compliance review of client files.
Helped implement a new AML Target
Operating Model for enhanced
regulatory compliance.
Conducted a review to enhance a
bank’s fraud risk framework, alert
scenarios, and also reviewed select
asset portfolios.
Assisted the bank in the
implementation of the AML
transaction monitoring and sanctions
screening solution for their operations
across the globe, including India, and
helped enhance and optimize the alert
clearance framework.
Reviewed a bank’s wealth
management process and internet
banking facilities to further enhance
their FRM framework.
Investigated allegations
of fraudulent overdraft
facilities against fixed
deposits.
Implemented an integrated
framework to manage the
risk of financial crime across
the customer lifecycle.
Assisted a bank in reviewing
and identifying gaps in
the sanctions compliance
framework.
Engaged to restructure and
integrate the compliance
function within a global
organization.
07
Financial Crime Compliance
Why choose Deloitte’s Forensic practice in India?
Deloitte has been at the forefront of providing services to help clients - especially for some of the leading financial institutions - to
help deal with myriad business and compliance issues presented by financial crime.
Financial services focused Forensic practice:
Drawing on in-depth sector experience and forensic
domain knowledge on engagements
Sounding board for Government agencies and
market regulators: Long standing and trusted
association with regulatory authorities
Diverse team skill sets: Drawing on our
expertise and qualifications – our capabilities
spread across the financial domain as well as
varied others such as chartered accountants,
CFEs, forensic accountants, economists,
mathematicians, computer forensic specialists,
engineers, lawyers, and professionals with law
enforcement experience
Dedicated industry experts: We have one
of the largest financial sector focused teams
(within the forensic practice) in India
Unparalleled ‘Senior Management’
Forensic experience: Collective Partner-
Director experience of over 250 person
years
Marquee credentials: Appointed to
conduct majority of the headline making,
high profile investigations in India
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company
limited by guarantee (“DTTL”), its network of member firms, and their related entities. DTTL and
each of its member firms are legally separate and independent entities. DTTL (also referred to as
“Deloitte Global”) does not provide services to clients. Please see www.deloitte.com/about for a
more detailed description of DTTL and its member firms.
This material is prepared by Deloitte Touche Tohmatsu India LLP (DTTILLP). This material
(including any information contained in it) is intended to provide general information on a
particular subject(s) and is not an exhaustive treatment of such subject(s) or a substitute to
obtaining professional services or advice. This material may contain information sourced from
publicly available information or other third party sources. DTTILLP does not independently
verify any such sources and is not responsible for any loss whatsoever caused due to reliance
placed on information sourced from such sources. None of DTTILLP, Deloitte Touche Tohmatsu
Limited, its member firms, or their related entities (collectively, the “Deloitte Network”) is, by
means of this material, rendering any kind of investment, legal or other professional advice
or services. You should seek specific advice of the relevant professional(s) for these kind of
services. This material or information is not intended to be relied upon as the sole basis for any
decision which may affect you or your business. Before making any decision or taking any action
that might affect your personal finances or business, you should consult a qualified professional
adviser.
No entity in the Deloitte Network shall be responsible for any loss whatsoever sustained by any
person or entity by reason of access to, use of or reliance on, this material. By using this material
or any information contained in it, the user accepts this entire notice and terms of use.
©2019 Deloitte Touche Tohmatsu India LLP. Member of Deloitte Touche Tohmatsu Limited
For more details, please reach out to:
Contacts
KV Karthik
Partner, Forensic
Deloitte India
T: +91 22 6185 5212
E: kvkarthik@deloitte.com
Nikhil Bedi
Partner, Leader, Forensic
Deloitte India
T: +91 22 6185 5130
E: nikhilbedi@deloitte.com

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Financial Crime Compliance: An Enterprise-Wide Approach

  • 1. Financial Crime Compliance It is no longer sufficient to ‘go it alone’ Forensic
  • 2. 02 Financial Crime Compliance The issue at hand Negative publicity, damage to corporate reputation and loss of goodwill, legal and regulatory sanctions and adverse effect on the bottom line – are all possible consequences of an organization’s failure to manage the risk of financial crime. With regulators adopting stricter regulations on financial transactions and enhancing their enforcement efforts, institutions are facing increased complexities in being compliant. With penalties for non-compliance only getting steeper, what financial institutions need to focus on today are not only the costs that need to be incurred on remedial measures but also improve processes and operational controls to help mitigate these risks in the future. Financial services organizations are struggling to manage and control elements of financial crime. The threat of financial crime runs the gamut of financial fraud and abuse, such as money laundering, bribery and cybercrime. It has therefore become too broad to be handled by established divisions or departments. An enterprise-wide approach is essential and should leverage new analytical software tools. The Financial crime lifecycle Monitoring and testing: Assessing financial crime systems and policies to ensure they are efficient and talloring systems to meet changing internal and external threats. Compliance: Acting in accordance with the requirements of relevant authorities by implementing governance structures and financial crime strategies. Investigation and remediation: Assessing allegations of fraud or financial mismanagement, responding to government regulatory requests, and helping financial services organizations remedy issues and prevent their recurrence. This invoices data assessment, e-discovery, understanding relevant laws and regulations, and undertaking cyber response activities. Prevention and detection: Reducing financial crime incidents and identifying early issues and risks by implementing effective operational controls. The focus is on enterprise fraud and misuse management using integrat4d technology platforms and advanced analytic. "Just because your bank's compliance challenges are unique does not mean you must tackle them alone"
  • 3. 03 Financial Crime Compliance What we can do for you Regulatory compliance | Anti-money laundering (AML) services Developing or enhancing your AML framework and/ or target operating model based on regulatory requirements and leading industry practices We have advised several financial institutions including global financial institutions in enhancing their AML framework and/ or target operating model. This includes undertaking gap analysis vis. a vis. local regulatory requirements, their global AML polices/ procedures and benchmarking them against industry practices. AML training for employees to facilitate knowledge and capability building We have helped conduct AML awareness/ training workshops for senior as well as middle management. This entails a comprehensive program tailored to every organization’s culture and product base to train and create awareness amongst staff on key AML issues. AML due diligence We have helped clients in getting clarity on the target’s business profile; KYC procedures; existing systems and controls; and overall compliance with AML legislation as part of a pre- acquisition review of the target’s AML systems and controls. Assist in transaction look back exercise We have assisted clients in undertaking a review of historical transactional data with respect to sanction screening and reporting of SARs (suspicious activity reports). Implementation or enhancement of your transaction monitoring system We have assisted Global and Indian clients in enhancing their transaction monitoring systems; including reducing false positives, enhancing/ developing the alert clearing process as well as quality assurance of their alert clearance process. Client on-boarding and remediation programs We have assisted clients in India as well as globally with planning and implementing account remediation/ periodic refresh exercises using an offshore model with inbuilt quality assurance processes and tools to manage this process effectively. AML Investigation We have undertaken some of the largest AML investigations in the country. We also have experience of having undertaken investigations on behalf of regulators for some of the largest financial institutions in the country. The International Monetary Fund estimates the amount of money laundered globally in one year is between 2 to 5% of the global gross domestic product (GDP).
  • 4. 04 Financial Crime Compliance Financial services: Banking Fraud risk management - We have helped several financial institutions in undertaking a review of their portfolio and enhance their fraud risk framework. The team has experience of undertaking work in retail and commercial asset portfolios and cybercrime risk. Forensic audit - We have assisted regulators in undertaking a review of non-performing assets (NPAs) declared by the Bank and under-reporting, if any. This included determining the actual value of NPAs, reviewing the systems and its deficiency, top management involvement, if any. Investigation - We have assisted Banks, Regulators and the Ministry of Finance in undertaking various investigations into allegations regarding employees including top management and determining process weaknesses leading to the incident. Stressed asset management - We have worked with a number of Banks and consortium of banks in undertaking a forensic review of the stressed asset portfolio to identify misuse of facilities granted by the bank including diversion/ siphoning of funds. We have undertaken more than 20 forensic audits which included three entities that were part of the top ten NPA accounts in India. Forensic data analytics/ Early warning system - Based on our experience of working with other financial institutions, our tools have been customized to identify patterns, nonobvious relationship identification and inductive analysis techniques to analyze your customer and transactional data which can identify potential outliers in the data, helping identify fraud risks sooner than later.
  • 5. 05 Financial Crime Compliance Financial services: Insurance Enhancement of fraud risk management framework - We have helped several life and non-life insurance companies in undertaking an independent assessment of their processes, identified gaps and recommended measures to enhance their fraud risk framework. The team has extensive experience of working across the entire insurance value chain from customer acquisition to policy management and service to claims management. We also support by carrying out strategic interventions wherever required so as to enhance the existing fraud management framework in their companies – by preparing an anti-fraud policy, by training their resources, by recommending and supporting implementation of a governance structure and framework. Claims management - We have worked with a large number of insurance companies – especially on the non-life insurance side – in developing a fraud analytics solution for the claims management space. The solution involves setting up of customizable business rules for the client which then enables the company to identify high risk claims at the claims notification stage itself and undertake enhanced due diligence measures for such claims. Customized investigation procedures - We have carried out claims investigation engagements in cases which are of sensitive nature or involve high claims pay-out. These type of investigations involve carrying out market intelligence procedures to identify if these are instances of fraudulent claims. We have supported insurance companies in carrying out mystery shopping exercises to check the efficacy and effectiveness of their anti-fraud controls. This has been across multiple areas including sales, distribution, customer service and claims. Insider Trading - We have also worked with a few companies across different sectors to investigate into allegations of insider trading made against senior management personnel. Setting up of fraud control units - Since the fraud management space in the Indian insurance industry is still evolving, we also help insurance companies set up their fraud control units – by putting in policies, procedures in place as well as loan staffing. Investigation of market abuse cases - We are the only Big 4 in India to have investigated all the high profile market abuse cases that have taken place across different types of capital market entities – asset management companies, brokerages, etc. These cases have also involved us working in close conjunction with the regulator. 01 02 03 04 05 06
  • 6. 06 Financial Crime Compliance Select relevant forensic credentials in the financial sector We have worked with multinational and domestic banks in the private and public sector, regulatory bodies and the government institutions to ensure enhancement of anti-fraud frameworks and financial crime compliance. Assisted a large global bank with reviewing and remediating more than 65,000 client files across multiple line of businesses to comply with revised standards of the Bank on a managed services model. Assisted a multinational bank with AML/KYC policy and procedures gap analysis subsequent to a revised AML global standards roll out. The engagement also included assisting the bank with reviewing and KYC upliftment for high and medium risk customer files for its India operations. Undertook forensic audit on more than 20 financial institutions to assess the quantum of loss to the banking system by a borrower. Conducted a detailed forensic review into money laundering allegations raised during a sting operation. Assisted a global bank in review of its Offshore Banking Business in light of heightened global issues around offshore banking. This included review of their AML framework and sample KYC compliance review of client files. Helped implement a new AML Target Operating Model for enhanced regulatory compliance. Conducted a review to enhance a bank’s fraud risk framework, alert scenarios, and also reviewed select asset portfolios. Assisted the bank in the implementation of the AML transaction monitoring and sanctions screening solution for their operations across the globe, including India, and helped enhance and optimize the alert clearance framework. Reviewed a bank’s wealth management process and internet banking facilities to further enhance their FRM framework. Investigated allegations of fraudulent overdraft facilities against fixed deposits. Implemented an integrated framework to manage the risk of financial crime across the customer lifecycle. Assisted a bank in reviewing and identifying gaps in the sanctions compliance framework. Engaged to restructure and integrate the compliance function within a global organization.
  • 7. 07 Financial Crime Compliance Why choose Deloitte’s Forensic practice in India? Deloitte has been at the forefront of providing services to help clients - especially for some of the leading financial institutions - to help deal with myriad business and compliance issues presented by financial crime. Financial services focused Forensic practice: Drawing on in-depth sector experience and forensic domain knowledge on engagements Sounding board for Government agencies and market regulators: Long standing and trusted association with regulatory authorities Diverse team skill sets: Drawing on our expertise and qualifications – our capabilities spread across the financial domain as well as varied others such as chartered accountants, CFEs, forensic accountants, economists, mathematicians, computer forensic specialists, engineers, lawyers, and professionals with law enforcement experience Dedicated industry experts: We have one of the largest financial sector focused teams (within the forensic practice) in India Unparalleled ‘Senior Management’ Forensic experience: Collective Partner- Director experience of over 250 person years Marquee credentials: Appointed to conduct majority of the headline making, high profile investigations in India
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