An effective article on KYC Compliance a Strategic Approach which needs to be adopted by banks world over

2. Preface
Hearty greetings from the Infosys Banking Capital
Markets team. On behalf of Infosys, I am delighted
to present the first issue of our journal “FINsights”, a
compendiumof articles,whichbringyouinsightsintothe
technology powering the financial services business The
aim of the journal is to bring you the latest in technology,
applied to your business scenarios, which will enable you
to win in today’s flattening business world.
The first issue of FINsights focuses on the wealth
management industry; an industry which is grappling
with multiple challenges. An increasingly demanding
and informed customer base, a challenging compliance
environment and the jostling for a customer centric
“trust” based role amongst trust banks, brokerages,
insurance companies and family offices make for a very
challenging business environment. This journal has
a set of articles which look at these and other unique
characteristics of the wealth management industry and I
hope that they will not only make for enjoyable reading,
but also help you in addressing some of your vexing
business challenges.
I would like to thank all the contributors from Infosys
Banking Capital Markets group and also Alois
Pirker from Aite group and Matthew Bienfang from
TowerGroup for their insightful articles. I hope you will
enjoy reading these articles as much as we have enjoyed
putting them together. Please do not hesitate to get in
touch with me in case you have any queries or comments.
I look forward to your feedback and suggestions in
making FINsights a relevant and topical journal.
Happy Reading!
AshokVemuri
SeniorVice President and Head - Banking Capital Markets Group
Infosys Technologies Limited

3. Contents
Preface
From the Editors Desk
04 Business Challenges and Technology Priorities
for Wealth Management
Ashok Vemuri
10 Integrated Advisor Workstation – A Roadmap
Merlyn Mitra | Anand Bhushan
19 Case Study: NextGen Client Data Aggregation
and Reporting
Ashwin Roongta
23 The Role of Open Architecture
Emmanuel Chesnais
27 Managed Products -
A Strategic Transformation Framework
Mak Datar | Sanjay Taneja | Rajeev Nayar
34 Holistic Wealth Management
and the Unified Household
Alois Pirker
39 Achieving Client Centricity via
Customer Data Integration
Sai Kishan Alapati | Ashwin Roongta
45 Product Repository: The Foundation for
Successful Open Product Architecture
Sai Kishan Alapati | Anita Stephen
49 Removing Glitches in On-Boarding the Wealthy
Muthukumar Krishnan | Sujata Banerjee | Bharat Rao
55 KYC Compliance - A Strategic Approach
Rajesh Menon
59 Analyst Perspectives - QA with TowerGroup
Matthew Bienfang

4. From The Editors Desk
The wealth management industry is changing rapidly to
meet the evolving needs of its participants. This is one
area where true financial services convergence seems to
be happening as trust private banks, brokerages and
retirement planning focused companies are all trying to
get a bigger slice of the action.
Opportunities in new geographies and asset classes are
driving a lot of the change in the industry today. These
will lead to increased investments in the core processing
platforms, as well as the need to tie the various platforms
together. The need to bring systems together is very
important to financial services firms from a financial
planning advice, customer data, client service and a
Business Intelligence (BI) reporting perspective.Open
architecture is another very important consideration
that is driving changes to the way the banks service
clients. Further, the need to offer clients a wide bouquet
of products is driving consolidation of information
across the different products and asset classes. Changes
in banker and advisor team structures as well as client
segmentation for servicing will lead to better cost
structures.
All of the above have technology implications for banks.
Technology will need to be aligned with business to
meet the needs of an agile organization that can respond
rapidly to changing business circumstances. Technology
itself is evolving rapidly and can sometimes drive changes
in the organization through the ability to deliver more
than what was hitherto considered possible. Information
Technology (IT) organizations that are able to plan and
react early, and then execute well on these changes are
the ones that will succeed in meeting the needs of their
business.
We are happy that this book addresses some of the
biggest business challenges and technology implications
addressing wealth management firms today. The debate
on some of these topics is very timely. We hope that the
journal will inform you and enable you to formulate a
response to the many challenges facing our industry. We
look forward to your feedback.
Happy Reading!
Balaji Yellavalli Manish Jha
Editors
FINsights Editorial Board
Balaji Yellavalli
Associate Vice President
Banking Capital Markets Group
Bhuvaneswari Sundaram
Associate Vice President
Banking Capital Markets Group
Jonathan Stauber
Vice President
Banking Capital Markets Group
Lars Skari
Practice Leader
Banking Capital Markets
Infosys Consulting
Manish Jha
Engagement Manager
Banking Capital Markets Group
Mohit Joshi
Chief Executive Officer
Infosys Technologies S. De RL De CV

5. 55
As an immediate response to the Patriot Act requirements, most organizations adopted a tactical
approach to their Know Your Customer (KYC) programs. Organizations are now looking to adopt
a more strategic approach to their KYC systems. Creation of single customer views enabling high
reusability of customer information, adoption of standardized client risk scoring models, techniques
aimed at moving towards straight through processing ensure a more efficient KYC process and a
reduction in the overall account opening timelines. This is yet another example of how an efficient
compliance program while meeting regulatory requirements can also serve as a competitive
differentiator.
Rajesh Menon
Senior Principal
Infosys Technologies Limited
KYC Compliance - A Strategic Approach

6. 56
World over, Anti Money Laundering (AML) regulation
has been intensifying and the risks of non-compliance
have become increasingly severe, including regulatory
crackdowns, impact on market capitalization and
customer perception, and potential financial instability.
In the United States, money laundering legislation has
gone through several transformations, culminating
in the USA Patriot Act, which requires all financial
institutions to establish AML programs, with Customer
Identification programs for both new and existing
customer relationships and transactions monitoring of
accounts for suspicious activity.
Key challenges in AML KYC compliance
As an immediate response to the Patriot Act
requirements, most organizations adopted a tactical
approach to their KYC programs. While this has
helped meet the regulatory deadlines, the efficiency of
the current systems and processes are not in line with
organizational objectives.
Some of the key challenges faced include:
Establishing a single view of the customer across
different LOB’s
Manualprocessesinthecurrentflowwhichintroduce
risk and reduce efficiency
Difference in the KYC procedures adopted across
the organization( especially relevant to organizations
with multiple LOB’s and a global footprint)
Inability to share KYC related information across
the organization
Ability to achieve Risk based surveillance.
Many organizations are now looking to take a more
strategic approach to their AML compliance programs
and wherever possible leverage synergies with other
compliance initiatives within the firm.
Strategic Approach to KYC Compliance:
The key organizational capabilities that financial
institutions need to build into their AML programs in
order to successfully meet the current challenges are:
Reusability of data and systems
Being able to reuse data and systems across different
parts of the organization and for different processes.
Creation of a Single Customer view
The capability to take a holistic view is critical, since
the most efficient way to uncover a money laundering
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scheme, is being able to access and correlate a range
of data about the client, the client’s associates and
transactions
Having a single view of the customer provides
benefits from both a client relationship management
perspectiveandaclientriskmanagementperspective,
given that a client and associates can hold numerous
accounts in different combinations across different
parts of a financial institution’s business, e.g.
mortgage, savings account, trading account, credit
card account, etc
While organizations can establish new procedures to
capture this information going forward, the greater
challenge relates to how the existing client data can
be leveraged to the extent possible.
Creation of global KYC hubs
Given the global footprint of today’s organizations,
firms are increasingly considering the creation of
global KYC hubs with data elements that cater to
the needs of the various local regulations in addition
to the US Patriot act requirements.
Increased scalability and flexibility
Having reusable data and system components
enables better scalability and the flexibility to use
those components relevant to a particular business
line, geographical location, reporting jurisdiction or
compliance report
Beyond AML: Overlapping regulations mean that
the data, reports and processes implemented for
AML can also be used to meet other regulatory
requirements, and vice versa. Therefore, reusable
data and system components can help to reduce the
overall cost for the organization.
Fig 1: Key drivers to strategic KYC compliance
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7. 57
Centralized Risk Management View
Establish a centralized risk management view, across
various divisions, systems and processes for effective
surveillance, internal information sharing and controls
and external reporting. Key drivers are:
Centralization of key surveillance functions such as
name matching against watch lists, high risk country
checks enables improved customer and transaction
risk assessment and analytics. Use of centralized
reference lists eliminates risks associated with
different regions/LOB”s using different versions of
the watchlist data
Consistency and coherence in the client risk
classification and KYC processes adopted across
the organization and improved information sharing
across business lines and geographical locations
Easy access to history of investigations on existing
customers, 314(a) queries. Apart from providing
valuable inputs to the alert resolution process or
responding to regulatory queries, this also ensures
that account opening systems across the firm
have access to the same quality of surveillance
information
Improved correlation capabilities, analytics:
Centralized surveillance also enables improved risk
analytics, better correlation across activities that
span various businesses or types of accounts .
Fig 2: Client risk scoring engine
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Automation of processes, Move towards STP
This is aimed at addressing the primary pain point in the
current KYC processes at most organizations. Precise
definition of documentation requirements, integration
with document management systems assists in making
the KYC flows ‘straight through’ with only exceptions
being flagged for manual reviews.
Automated processes improve efficiency, enabling rapid
turnaround and ease of portability, while simultaneously
reducingoperationalrisk,bothaccidentalandintentional
associated with manual processes. Other Drivers
include:
Better connectivity: Automated processes reduce
‘silo’ization of the organization and reliance on email,
fax, and courier for collection and transmission of
customer data, especially at the customer acceptance
stage
Avoid potential gaps in data gathering: Automated
processes can reduce gaps in data gathering,
ensuring that all relevant data is captured at each
step and reducing the risk of failng to comply due to
incomplete or incorrect data
Better information dissemination: Automated
processes also enable efficient transmission of
tasks and workflows across organizational areas or
locations.
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8. 58
Fig 3: Best practices in KYC implementation
Conclusion:
While the emphasis over the past couple of years has
been to establish a basic surveillance program across the
organization, the current emphasis clearly is to increase
the efficiency and effectiveness of the current processes.
New regulations like section 312 have ensured that
the KYC area continues to stay in regulatory focus.
With regulators increasingly emphasizing on enterprise
wide programs which adopt a risk based approach to
surveillance,the process of replace tactical solutions with
more long term approaches has been further hastened.
Rajesh is a Senior Principal Practice Lead with Infosys’ Banking Capital Markets practice for compliance solution
offerings. He has over 14 years of experience in the Financial Services industry and has been involved in advising several
Wall Street firms in various aspects relating to their AML program implementation.
Rajesh Menon
Senior Principal
Infosys Technologies Limited