COVID-19 has not only led to a shift in the risk a customer may represent to a firm, but has also impacted the operational landscape of the financial services industry. Firms have had to quickly adjust to change, with notable scenarios including:
- Changes in both customer and bad actors’ behaviour resulting in traditional monitoring scenarios and risk scoring thresholds becoming outdated.
- Impacts on an individual’s ability to prove their identity leading to increased levels of financial exclusion for prospective customers.
- Challenges for firms in meeting CDD obligations due to issues in collecting documentation and difficulties accessing paper-based files and documents.
Rapid adjustments towards digital transformation have been made by firms in order to address these issues.
Conclusion
As a result of wider changes originating from the pandemic, many firms may already be executing or in the process of planning digital transformation programmes, and this presents a great opportunity to either incorporate Financial Crime Compliance within scope, or utilise the infrastructure developed under digital transformation programmes to enable better financial crime controls. At the same time, firms should keep in mind that implementing an effective digital transformation programme needs to ensure that operational risk and disruption is minimised.