PwC has a proven experience in the enhancement of KYC processes and in building up an efficient and robust AML/CTF framework.
Financial institutions around the world continuously struggle to respond to financial crime. Meanwhile, law enforcement agencies and financial regulators have placed the fight against money laundering and terrorist financing at the top of their agenda, and continue to tighten their demands and requirements. Money Laundering (ML) and Terrorist Financing (TF) cause financial losses, fines, and operational headaches.
Financial institutions must be in a good condition to defend themselves against ML and TF threats, and to try to prevent related incidents.
Is your institution fully equipped to take on the fight against financial crime? Considering the increased risks, and the opportunities available through new digital solutions, it is time to assess whether element(s) of your Anti-Money Laundering (AML) and Know Your Customer (KYC) processes could be upscaled.
Our team of specialists will work with you on the development and implementation of solutions that are suited to your requirements and tailored to your needs.
With the EU’s AML Regulation, AML Authority Regulation, AML Directive VI (preceded by AML Directives IV and V), the associated national implementing regulation and European Banking Authority (EBA) Guidelines and Implementing and Regulatory Technical Standards, the European Central Bank (ECB)’s integration of money laundering (ML) and terrorist financing (TF)- related risks in the Supervisory Review and Evaluation Process, the Financial Action Task Force Recommendations, the Wolfsberg Principles (and related Questionnaire), and the Guidelines from the Basel Committee on Banking Supervision, the AML and CTF regulatory landscape is becoming an almost impenetrable jungle.
The detection of money laundering and terrorist financing in an organisation depends heavily on data quality; think about the huge amount of information coming from customer identification and verification, customer segmentation, transactions and third-party sources.
IT systems and applications can help, but the number of services and tools on offer is soaring, and it is becoming increasingly difficult to distinguish between what constitutes added value, and what doesn’t.
KYC obligations require large teams of analysts to process client files, and the fact that such reviews need to be done periodically doesn’t help.
In addition, client outreach requests place a heavy burden on the Front Office, while Compliance teams may struggle to develop suitable policies and procedures, monitor high-risk customers and products, and fulfil reporting obligations.
To find experienced staff on the market is not easy! The specific expertise needed within KYC teams can quickly lead to bottlenecks, delays and large backlogs when key personnel drop out.
Institutions providing products or services labelled as high risk (such as Private Banking, Correspondent Banking, virtual currencies, etc.) and/or serving clients in high-risk industries (diamond sector, construction & real estate, gambling, etc.) face even stricter AML monitoring and reporting requirements.
This may lead to institutions moving away from offering these kinds of products and services and clients in high-risk industries being unable to access financial services. Supervisors have spoken out against such broad “de-risking” measures. Financial institutions need to tread a fine line between excluding entire categories of customers and properly managing individual clients involved in higher-risk products and industries.
The most direct impact of ML/TF accusations on financial institutions’ reputation is through fines and newspaper headlines. There are other factors to consider though: consumers are increasingly demanding a streamlined onboarding process, and the relationship with loyal clients might be undermined by inefficient KYC procedures.
The 2025 AML Package established AMLA as a new and independent supervisory authority at EU level, dedicated to the fight against money laundering and terrorist financing. AMLA started operations in 2024 and is in a foundation phase until 2027, at which point it is expected to reach full capacity. AMLA will carry out the following tasks:
Direct AML/CTF supervision: AMLA will directly supervise up to 40 cross-border financial entities that present the highest risk profiles regarding money laundering / terrorist financing. The selection of supervised entities will happen through a harmonised methodology, with a point scoring system to determine residual ML/TF risk. The initial selection process will take place in 2027 and will be repeated every three years. Actual supervision will start as from 1 January 2028. Supervision will be conducted by Joint Supervisory Teams comprising both AMLA and national supervisors. AMLA will have the power to impose administrative measures and pecuniary sanctions to penalise non-compliance. Financial institutions that do not meet the criteria for direct supervision will continue to be supervised by national authorities.
Regulatory development and cooperation: AMLA will develop regulatory and implementing technical standards and guidelines to complement EU AML/CFT rules. In addition, it will assist in the convergence of supervision and foster a common AML/CFT supervisory culture within the EU.
PwC has proven experience in the enhancement of KYC processes and in building up an efficient and robust AML/CTF framework.
Developing a strong AML/CTF operating model that aligns with the nature of your business and types of clients, drafting and optimising operational policies and procedures, providing KYC analysts and subject matter experts, performing client outreach and quality assurance, and developing and facilitating the implementation of KYC tooling are just some of the ways that PwC can support you.
Conduct an exposure analysis of the organisation based on key criteria to establish a compelling business case.
Conduct an exposure analysis of the organisation based on key criteria to establish a compelling business case.
Translate legislation and regulatory requirements into policies and procedures fitting your organisation.
Assess, select and facilitate the implementation of a wide variety of AML/CTF applications and/or KYC modules.
Review your MIS to improve decision-making efficiency.
Assist you in developing a risk assessment framework and the underlying methodology.
Increase the level of AML/CTF knowledge and awareness of your entire staff.
Effectively manage incidents that may create regulatory or reputational risk.
