Our First Implementation – The journey of a thousand miles has begun with the first step
(Oracle Financial Crime and Compliance Management (FCCM) – Anti-money Laundering (AML) & Regulatory Reporting Solutions)
by Asif Ali Khan, Consultant, bfsi Consulting
“Sure I am this day we are masters of our fate, that the task which has been set before us is not above our strength; that its pangs and toils are not beyond our endurance. As long as we have faith in our own cause and an unconquerable will to win, victory will not be denied us.”
“Winston S. Churchill”.
It was December 2014, after a long wait I was excited as our first Oracle FCCM – AML project was to start. After initial preparations I was ready to head to client site to start the project.
On a scheduled day, my colleague Tony and I left for Manila to kick-off the project. We landed and saw that Manila city was similar to a metropolitan in India only with a little more discipline, people were following traffic rules and it was better organized. India shows more diversity and tolerance towards all beings, but in Manila I could not see any animals sharing the road space.
The bank had made arrangement for accommodation in a condotel close to office, it was comfortable and sufficient for our needs.
I was excited as this was my first implementation project. There was also certain pressure and responsibility to succeed since this was the first project for all involved parties (bfsi, Oracle and the Local partner) in this region. There was a lot of credibility and reputation that had to be protected and upheld.
In the recent times, there has been a tremendous focus on AML and Regulatory compliance across the globe. The reasons for these are increased regulatory pressure and banks’ goals for long term growth and sustainability. The industry is embarking on what is called the second wave of compliance investments. Financial institutions are moving away from a simple rule and threshold based monitoring to a more complex behaviour detection to identify and report suspicious activities/transactions. Hence, a need for advanced transaction monitoring tools.
When bfsi recognized some of the risk and compliance opportunities in APAC region – Philippines in particular, they wanted to build their capabilities in this area. In this effort, they chose me. I was the first member of the FCCM team. A Certified Anti-money Laundering Specialist (CAMS) having experience in operations and different projects across Know Your Customer, Anti-Money Laundering (AML) Transaction Monitoring and Foreign Account Tax Compliance Act. While I had been part of various compliance projects and worked in AML operations too, this was to be my first implementation project, as well as bfsi consulting’s. Hence this was a challenging assignment. Co-incidentally this was also Oracle’s first FCCM-AML implementation in Philippines.
Unionbank of the Philippines, this was one of the largest banks and well known for adapting new Information Technologies to continuously improve quality of its systems and processes to be on par with international standards. The bank has 192 branches. They had a mandate from their regulator “Bangko Sentral ng Pilipinas (BSP) to implement a new efficient electronic monitoring system under 6 months. .
I had started working with the client on preparatory activities well ahead of the project kick-off. AML & RR systems require data feed as per certain specifications, and this is important to a successful implementation within the stipulated timelines. Since the timelines were short and the task at hand was big, we planned all the activities and listed out as many risks and challenges that we could foresee. We also devised some strategies and remedies to mitigate the risks and overcome the challenges.
We kicked-off the project with a presentation that was well received. Next was to start installation. Here come the problems – We encountered issues as IT infrastructure were not ready with the required software. Delays, of course, but we patiently explained all requirements and co-ordinated with banks IT to get the environment up and running. The banks IT was responsive and ready to help.
Also noticed, one of the country specific solution pack was not ready and we had to manage that.
The quote you read at the start of this article is my favourite and I always take inspiration from it in difficult situations. The RR application was under development for some time but it was anticipated that Oracle will deliver this by the start of the project. Unfortunately, it got delayed. While we were working with Oracle on development, we convinced the bank that the implementation will be managed without impact on delivery and quality. For this, I modified the project plan considerably to suit the delivery timelines and managed to proceed with AML activities that were major part of the project. Adding to this we also had to customize an automated Covered Transaction Report (CTR) report for the bank as per BSP’s new format as well as other internal reports.
Let me share the people experience in Philippines. Philippino’s are usually soft spoken, polite and friendly. Most of the population speaks English that is really helpful. The bank team was very meticulous in documentation and keeping records. While we also work with all necessary documentation and records, it was still a great experience and learning for us to align our documentation with their requirements. We made some good friends from compliance team with whom we visited couple of good beaches and Taal volcano.
Philippino food was not to our liking. It was early days when I and my colleague went out to explore the local cuisine. We saw some joints that were displaying various dishes, most of them looked delicious and we wanted to try. We saw chicken with bright sauce/gravy that looked spicy and ordered it with some rice. When we tasted it, we looked at each other and wondered if we had ordered a dessert before the meal. It was sweet and we were disappointed. After many experiences we understand most of the local food there was not suitable for our Indian palate. However, we found some places and dishes that were good and suited our palate. Also found Indian food delivery service during the last days and cursed ourselves for not discovering it early.
We faced some substantial challenges in data preparation. We did multiple mock and pilot runs extending and overlapping in other project milestones/activities. This helped us to finally achieve the desired level of data integrity. The bank too worked hard to get this right. All the planning that was done well ahead proved to be crucial to accomplish this.
When the regulatory reporting module was released, a significant milestone was crossed. But our problems were not over yet. We had to upgrade the entire software to a higher version due to certification issues. We worked extended hours and weekends to prepare the environment for production. We were then to train the core team on Philippines STR and assist in UAT. However, things went well and the bank completed UAT.
In-spite of certain issues and problems, we were successfully able to Go-live on the scheduled date. Thanks to Tony, he worked hard on the technical delivery aspects. All the parties (bank, bfsi, Oracle and the local partner) involved were happy and satisfied. A sense of accomplishment and happiness enthralled us. We were able to deliver to management’s expectations. This was also the first Oracle AML project to Go-Live within 6 months. The bank was appreciative and delighted with our efforts.
Key factors that contributed to the success of the project were clear communication on the status and issues, improvisation and agility anticipation of risks and challenges and hardwork.