SITUATION – The client was a fully integrated Fund and Corporate financial services provider, aligned to international private equity & infrastructure houses, real estate firms, private debt managers, multinationals, capital markets issuers and high net-worth private clients, headquartered in Luxembourg. The technology deployed in the business meant that they were largely in a low risk scenario from a GDPR breach risk perspective, however they were unable to meet many GDPR requirements. The compliance gaps were exacerbated by the complexity and wide range of their business activities. Most standard operating procedures were documented in 150+ formal documents of varying currency and format.
SOLUTION – Engaged as lead business process analyst to verify, document and analyse all operational processes, client services processes and business development & marketing processes to support a global process review and improvement initiative. Interviews were held with 100+ stakeholders, managers and staff, who were supported through the verification, analysis and documentation activities.
We defined the project’s analysis approach, (approved by project management, group DPO & legal counsel), and recruited an additional team member. We ran workshops and 1-2-1 meetings, both remotely and face to face in London, Luxembourg and satellite offices abroad. We verified process data and gap analysed the same, risk assessed processes and information assets and produced and maintained an enterprise level process analysis dashboard to track the workstream progress.
Our deliverables informed various regulatory documents, supported information governance standard procedures and drove multiple GDPR programme activities including legal compliance and systems security and compliance workstreams.
OUTCOME – We delivered our findings which fed into various other workstreams, operational procedures and formal documents. The process improvement programme as a whole faltered when the newly appointed UK based executive team were ousted by the Luxembourg based owners in Spring 2020 which resulted in a string of departures.
The in-scope processes covered:
Sales, Marketing, HR, KYC Compliance, Common Customer Processes, Corporate Business, Finance, Fund Management, Consolidation, Liquidation, Transfer Pricing, Business Office Services, Internal Operations, IT, Depository Services, FATCA-CRS, Business Continuity Planning, Corporate Governance and Information Security.
More about the client:
They provided corporate and management services, (including incorporation, management, tax compliance, consolidation, administration and accounting, statutory audit), and liquidation services for private equity, real estate, multinationals, and private clients.
The company also provides fund services, (such as fund launch, accounting and bookkeeping, middle and back office administration, net asset value generation, reporting, company secretarial and infrastructure support, carried interest administration), and investor communication services for private equity and real estate funds, financial reporting, hedge funds, and infrastructure clients.