What makes a great KYC Analyst?
Vice President - Compliance
Wednesday 19 June 2019
The costs of KYC
Since the introduction of the First EU AML Directive in 1993 , KYC (Know Your Customer) has become permanently embedded within Financial Services operational environments. Large Financial Services firms now spend an average of $150 million annually on KYC processes (up to $670 million if remediation programmes are included) . Given this level of expenditure and the current pressures on over-stretched budgets, dealing capably with KYC in a cost effective manner is a key consideration for industry decision makers.
Technology solutions have helped to reduce some headcount costs through the automation of certain aspects of the KYC process. In addition, machine learning will play an enhanced role in helping to rationalise processes and minimise associated costs in the years ahead. Managed service outsourcing arrangements can also deliver cost-savings of 35-60% and improvements to the efficiency of KYC operations through access to wider talent pools in lower cost locations. However, despite these innovations, staff costs still account for 64% of annual KYC expenditure, and identifying effective people to conduct KYC remains an important priority. 
The importance of the KYC Analyst
A popular misconception about KYC is that it is solely concerned with collecting and verifying documents and information. While this is certainly an integral part of the role, KYC is, in practice, significantly more complex and multi-faceted. Amongst other things, KYC Analysts will invariably require knowledge of customer behaviours, interact extensively with a broad range of stakeholders, have the ability to analyse and contextualise information and be able to understand risk and compliance issues.
The benefits for Financial Services firms in having highly effective KYC Analysts are clear:
they help to positively impact financial performance and revenue by expediting the swift onboarding and continuation of revenue generating customer relationships;
they help to ensure compliance with a firm’s regulatory obligations and to avoid regulatory fines or censure;
they can positively enhance a firm’s reputation by acting as a knowledgeable and professional point of contact prior to the establishment of a customer relationship, or at periodic points during the lifetime of a customer relationship; and
they act as a gatekeeper to help manage and mitigate a firm’s overall reputational, regulatory and financial crime risk exposure.
The hiring of a KYC Analyst is therefore a matter that necessitates careful consideration - choose well and a firm will have somebody that adds value and is an ongoing asset to the business; choose badly and the detrimental impact may be felt across multiple business areas as well as with external stakeholders. It is equally important from the employee perspective that if a person is working, or intends to work, in KYC that they are aware of the qualities they need to possess and/or enhance to be successful in the role.
Quality vs. Time
When gauging the aptitude of a KYC Analyst, the key evaluation tool for firms is productivity i.e. the ability of the Analyst to process and complete client KYC files in as short a timeframe as possible. The core tenet of this productivity, which will allow an accurate assessment to be made of an Analyst’s effectiveness and suitability for the role, is the balance between quality and time when processing a KYC file.
The below chart illustrates this balance, plotting the length of time taken by four Analysts to process a KYC file, against the quality of that file.
An Analyst performing in the upper left quadrant will be above average in terms of both quality and time taken to process a KYC file. Analyst 1 is the best performing Analyst and will progress KYC files to the quality control stage very quickly, with the files consistently characterised by a low number of errors. The extent of remediation work to be carried out by the Analyst after quality control is therefore minimal, resulting in shorter overall completion timeframes and a high productivity rate.
Analyst 2 is performing in the lower left quadrant of the chart. Similar to Analyst 1, he/she will also progress KYC files swiftly to the quality control stage. However, the standard of the files will be much lower, with many errors coming to light at the quality control stage. The subsequent time taken by the Analyst to rectify these errors will translate into longer overall end-to-end completion timeframes and a markedly lower level of productivity when compared to Analyst 1.
Analyst 3 will process KYC files to a very high standard, but in doing so will take a significant amount of time. The Analyst might be processing files in an overly complicated manner, applying a level of investigatory depth that is not necessary or warranted. While it may seem worthwhile to take extra time and aim for perceived perfection, such an approach and mind-set runs the risk of unnecessarily prolonging the time taken to progress the file, to the detriment of overall completion timeframes and the Analyst’s personal productivity.
Analyst 4 is the worst performing KYC Analyst, with the lowest productivity of all those represented on the chart. The quality of Analyst 4’s KYC files are poor, with a long time taken to progress the files to quality control stage and many errors to remediate.
Quality vs. Time is a challenging balancing act for a KYC Analyst and many will struggle to achieve the optimum balance of high quality/low time that translates into the highest levels of productivity. However, exceptional Analysts will be able to consistently demonstrate effective analytical and decision-making skills that allow time and efficiency savings to be made, without unnecessarily compromising quality.
The following example illustrates traits associated with a top performing KYC Analyst. In this scenario, a missing KYC document is required to verify the ownership structure of a low risk corporate client:
KYC Analyst A searches for and eventually locates the required document, but only after he has spent four hours exploring all potential sources, including stakeholder outreach and internal escalation channels;
KYC Analyst B spends one hour unsuccessfully trying to locate the same information. Based on the low risk level of the client and the anticipated low volume of transactions attributable to the client, the Analyst then changes her approach and spends one further hour obtaining two alternative pieces of evidence with which to verify the client. Although the alternative evidence is not specifically referenced in the KYC Policy, she believes that it will be acceptable and in line with the firm’s risk-based approach to KYC - this assertion is later proved correct when the file is reviewed at quality control stage.
KYC Analyst B has shown initiative by assessing the various options and applying a pragmatic and solutions-focused approach to the problem. By adequately resolving the issue in two hours rather than four hours, her productivity is twice as high as Analyst A.
The goal for all KYC Analysts is clearly to deliver exceptional productivity through the consistent completion of high quality, time efficient client KYC files. Achieving this will largely identify a great KYC Analyst. However, a number of important personal attributes and behaviours, some of which are evident in the above example, will need to be consistently displayed by an Analyst in order to attain and maintain this level of competence.
Pragmatic and solutions-focused
A great KYC Analyst will regularly apply a dose of pragmatism and demonstrate a realistic approach to issues based on practical considerations. When applying a risk-based approach to KYC - a key ingredient in all KYC Policies - there is often space for an Analyst to develop creative alternatives to overcome obstacles that are blocking progress. As demonstrated in the practical example above, an exceptional Analyst will possess the awareness to think outside the expected norms and focus on all available options to progress a client KYC file more efficiently to completion.
Professional and effective communicator
A KYC Analyst role involves extensive data analysis and research, and the subsequent recording and reporting of resulting observations and findings. It is therefore crucial that a successful Analyst possesses strong verbal and written communication skills when presenting information and interacting with customers, stakeholders and colleagues. By contrast, a KYC Analyst who is unprofessional, inappropriate and/or impatient in written and verbal exchanges with stakeholders may cause reputational damage, leading to customer dissatisfaction or, in extreme circumstances, the loss of customers or contracts. These negative traits and consequences may also cause damage to the Analyst’s personal and professional reputation.
Self-managed and organised
KYC Analysts, notably those working in outsourced KYC utilities, will often operate in large teams as part of busy and constantly changing work environments. They may have several competing priorities across numerous client files, such as compiling initial KYC requirements, responding to emails and queries from stakeholders, or dealing with required management information requests. A great KYC Analyst will be able to prioritise effectively and act to ensure that potential for progress across client files is maximised and all necessary deadlines are met. The inability to adequately self-manage workloads or perform required management tasks will compromise individual productivity and place strain on the ability of workflow managers to maximise wider KYC operational effectiveness.
Adaptable and resilient
KYC roles regularly throw up new and challenging situations. Goalposts shift and roadblocks often appear that impede the ability of the KYC Analyst to perform. An exceptional KYC Analyst will display resilience, deal positively with adverse impacts or disruptive change (or in certain situations the lack of necessary change) and adapt by looking ahead and embracing any new norms. Demonstrating such traits will identify Analysts as an example for their peers to follow. By contrast, Analysts who are unable to effectively deal with these influences will often retreat and allow frustrations to negatively influence their own performance and that of others.
Taking responsibility for changing oneself in order to drive the development of the above behaviours is a crucial self-improvement characteristic that marks the best KYC performers out from the crowd. Like any top-level employee, a great KYC Analyst will critically self-assess their performance and think carefully about steps they need to take to effect positive change. By stepping outside the comfort zone and taking action to change oneself, growth and enhancement will undoubtedly occur in the context of being able to succeed in the role.
In summary, what makes a great KYC Analyst is optimising the Quality vs. Time balance through the effective application of the traits and behaviours discussed above. Some of the traits may already be part of an Analyst’s skill set, or they can be developed over time with experience, self-learning and the guidance of managers and others. While not an exhaustive list, these qualities will together provide a strong foundation for achievement and place an Analyst within the highest KYC performance bracket.
Vice President - Compliance
Gareth has over 13 years’ experience in the Financial Services industry having worked in operations, regulatory compliance and project management roles during that time. He holds a Law degree, awarded by Queens University Belfast.
Prior to joining FinTrU Gareth worked for a global fund management company in Dublin for six years where he was responsible for managing regulatory and financial crime compliance for a number of Irish and Luxembourg domiciled UCITS and non-UCITS collective investment schemes.
On moving back to Belfast in 2012 Gareth worked for Ulster Bank as Project Manager on their AML Change Programme before working for a leading money remittance firm where he managed their global compliance.
Most recently Gareth worked for Citi as Regulatory Reporting QA Manager, responsible for assuring the quality of transaction reporting submitted to the FCA for multiple product flows across a number of Citi entities.
At FinTrU Gareth is a member of the senior management team with previous responsibility for delivering a KYC remediation project for a London based Tier 1 investment bank client. He is currently working with a local commercial bank client to deliver a number of financial crime compliance monitoring reviews.
Founded in December 2013, FinTrU is a multi-award winning Financial Services company that is committed to giving local talent the opportunity to work on a global stage with the largest international investment banks. FinTrU provides its clients with high quality, cost-effective, near-shore resourcing solutions. FinTrU’s products are: Legal, Risk, Compliance, KYC, Operations and Consultancy. Its clients are all Tier 1 Investment Banks based in London, New York, Tokyo, Frankfurt and Paris. FinTrU currently employs 360 staff at its two Belfast city centre offices and Derry/Londonderry.