Improving efficiency in compliance controls is vital for financial institutions to streamline processes, enhance risk management, and meet regulatory requirements more effectively.
Use cases
Pave the way of Financial Security
DynaFin's Expertise in Regulatory continuous improvement
USE CASE
Pave the way of Financial Security
Context
The National Regulator performed an audit of the bank’s ability to prevent and detect suspicious activity in clients’ financial transactions. Identified breaches led to recommendations focusing on improving Know Your Customer (KYC) and Anti-Money Laundering (AML) processes, enhancing global governance in detecting suspicious activities, and reviewing past activities. Upon agreement with the regulator, the bank delineated specific actions to address each recommendation and enlisted DynaFin of a consulting firm to aid in the deployment and governance of these actions.
DynaFin's Strategic Intervention
DynaFin played a crucial role in facilitating the deployment of the action plan, providing comprehensive support across various levels of the program:
Global Coordination of the Program
Our consultants assumed responsibility for overseeing the overall coordination of the program, ensuring alignment between different stakeholders involved in the remediation efforts.
Elaboration of Action Notes for the Authorities
DynaFin’s experts collaborated with the bank's internal teams to draft detailed action notes outlining the remediation measures implemented in response to the audit findings. These action notes served as formal documentation addressing regulatory concerns and were presented to the relevant authorities for review and approval.
Governance of Streams
Our consultants took charge of governance of different streams, ensuring that actions were effectively delineated and executed within their respective scopes. Consultants meticulously elaborated on the remediation actions within each stream, documented them comprehensively, and closely monitored the deployment process.
Implement sustainable solutions
Consultants actively participated in project squads dedicated to deploying structural solutions aimed at addressing the actions identified by the program. These project squads leveraged their expertise and resources to implement sustainable solutions tailored to the specific requirements outlined in the action plan, thereby driving tangible progress towards achieving compliance and regulatory adherence.
Files analysis
In the operational departments within the bank, consultants participated in Know Your Customer (KYC) and Anti-Money Laundering (AML) analysis of past files. This involved conducting thorough reviews of historical data, identifying any deficiencies or anomalies, and documenting them.
Outcome
With the assistance of DynaFin, the bank effectively addressed and resolved the audit findings, demonstrating a proactive commitment to cultivating a culture of regulatory compliance. Through collaborative efforts, the bank not only remediated existing issues but also laid the groundwork for sustained regulatory framework in the future. Structural solutions were successfully implemented, highlighting the bank's dedication to upholding the highest standards of compliance and governance, ensuring a robust and resilient foundation for long-term financial security.
Assistance in QI periodical Review
DynaFin's Expertise in Regulatory continuous improvement
USE CASE
Assistance in QI periodical Review
Context
The Qualified Intermediary (QI) regime is US Tax regulation where a QI, any foreign intermediary enters into a qualified intermediary agreement with the US Tax authorities (Internal Revenue Service).
This QI agreement allows the intermediary to simplify its obligations as withholding agent on U.S. source income (interest, dividends, and other fixed or determinable annual or periodical “FDAP”).
In this context, a large Belgian bank required to periodically review his withholding agent activities under its QI agreement has launched a project for the preparation of its QI periodic review.
DynaFin's Strategic Intervention
DynaFin Experts have assisted the Bank on the different QI obligations in view of their QI Periodic Review.
Design of procedures
DynaFin experts have drawn and formalized the end-to-end QI procedures of the Bank that describe the controls, the documentation and reporting of QI customers population.
Documentation review
A team of KYC experts have audited and remediated all the customer files (private individuals and legal entities) to ensure that customers are effectively entitled to the double taxation withholding tax rate.
US withholding tax
A review of applied US withholding tax rates to Fixed, Determinable, Annual, Periodical (FDAP) incomes have been performed according to the documentation provided by the customers.
Reporting
A team of reconciliation experts have prepared the yearly and periodical reporting has been prepared and provided them to the Internal Revenue Services (i.a. 1099 and 1042).
Outcome
With the assistance of DynaFin, the Bank was prepared to succeed in its QI periodic control to confirm the respect of the obligations provided by the QI agreement.
Enhanced Regulatory processes for FATCA/CRS
DynaFin's Expertise in Regulatory continuous improvement
USE CASE
Enhanced Regulatory processes for FATCA/CRS
Context
Financial Institutions outside the US territory is required to perform specific due diligence procedures with a view to identifying US persons (natural and legal) and report them. A similar initiative was launched at the international level and has resulted in the Common Reporting Standard (“CRS”) to reduce global tax evasion.
A Belgian insurance company, required to comply with this regulation in all its activities – has launched a regulatory program to align with in force regulations (including FATCA and CRS).
DynaFin's Strategic Intervention
The company has assigned DynaFin and its tax regulations experts to assist in completing the reporting obligations and reviewing their process and improving their controls.
Preparation of the FATCA and the CRS reporting
Our experts have made a detailed reviewed of the customers population (private individuals and legal entities) to be reported under these regulations and implemented the new reporting requirements published by the US Tax authorities (Internal Revenue Service). They have also implemented sanity checks to be yearly performed in the preparation process of these reports.
FATCA internal Audit
DynaFin has tested the effectiveness of the process for identifying consumers who are reportable and for reporting these customers, which resulted in a series of improvement recommendations.
FATCA/CRS remediation
Our team of DynaFin experts started a remediation campaign to contact and obtain valid and updated documentation from the entire impacted customers population.
Process alignment and improvement
We implemented new identification controls in the 1st Line of Defence and a enhanced governance, which led to a secure end-to-end process and compliancy with FATCA and CRS regulations.
Outcome
The insurance company has reviewed its entire FATCA and CRS population and has reinforced its customers database with periodical controls via a strong monitoring of the changes of circumstances with a higher quality of reporting.