In 2020 the internationally active insurance company has conducted a risk assessment, identifying 25 subsidiaries, that are liable with regard to the Money Laundering Act (GwG). Of these 25 subsidiaries eight prioritized subsidiaries were identified for the implementation of a comprehensive AML solution.
It has been the project’s objective to develop an overall rollout strategy and to manage a rollout for eight initial subsidiaries. A service provider and a specific AML tool had been chosen well in advance, while contracts and licensing still had to be concluded, alongside the creation of a project organization and communication.
Due to limited capacities, the overall project was split into several rollout waves, as only a specific number of rollouts could be executed simultaneously.
Wave 1 was considered a prototype and split into 4 phases, which structurally served all subsequent waves.
1. Strategic and risk-based prioritization of all subsidiaries in regard to each wave.
2. Introduction of the legal requirements, compliance guidelines, AML solution and generic rollout process.
3. Rollout preparation including 8 subsidiaries.
4. Requirements handover to the internal IT provider and the external AML solution provider concerning the implementation and rollout of the AML solution.
The structure of the project was generically drafted and handled. A product documentation was drawn, and project communication established. All regulatory, subject-specific and IT requirements were gathered, structure, assessed and handed over to IT.