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When a bank decides to exit a customer relationship due to financial crime risk, reputational concerns, or other factors, they must follow a careful process.

Regulations stipulate that banks should discuss the matter with the customer where feasible and secure additional information or funding to address concerns.

However, some situations make engagement inappropriate or impermissible, like fraud or threats to staff.

In this post, we share some of our thoughts on strengthening your exit process from a process and technology perspective.


Increased complexity:


For banks and financial institutions with multiple business units, pursuing exits consistently across the organization presents difficulties. Different client segments may have a different risk tolerance or a different view of a customer than the other.

This fragmentation can lead to contradictory actions, sending mixed messages to customers. Lack of coordination also risks regulatory scrutiny if exits appear arbitrary or unfair.


Banks must unify processes and leverage Technology for defensible exits:


To overcome potential challenges, banks need unified processes and supporting technologies.

Reliable Client Lifecycle Management and Case Management systems are critical to this process but require enhancements to support them efficiently. Systems need to provide auditability but also document actions and decisions systematically.

We believe there are 3 key capabilities needed to strenghten client relationship exits:


1 – Leveraging existing data and information:


Leveraging existing data and information from processes such as KYC and Due Diligence and ensuring it can be utilised by your case management and workflow solutions guarantees you are providing a consistent level of customer experience to support defensible relationship exits.

We believe a Customer 360 view, and Perpetual or Continuous KYC are becoming strategic priorities that need to be at the forefront of all Financial Institutions’ process and technology landscape.


2 – Advanced Analytics:


Analytics like negative news screening help connect the dots across disparate data sources. By flagging potential reputation, sustainability, or political risks, this intelligence gives you a stronger view of your customer and their risk.

We’ve previously deployed screening solutions that reduce reliance on 3rd party providers whilst reducing manual activities and being conscious of alerts and false positives.

In turn, banks can act decisively at trigger events like crime or controversies. Ongoing monitoring capabilities and reviews further ensure the exit process remains aligned with the bank’s risk appetite and regulatory requirements.


3 – Synergised processes and technology:


Financial Institutions tend to struggle to align data and technology against changes to their processes and policies, especially in the midst or after large transformation programs.

It is important to review the data available to your Financial Crime, Fraud and Compliance teams and understand what data can be utilised by your processes, cases and tasks, and to align that to the technology and strategic solutions that your organisation currently uses or plans to implement.


We believe that with these 3 capabilities, banks can conduct compliant and consistent exits. This limits their exposure to regulatory and reputational risk and ensures they treat customers fairly.

Exits are complex, high-stakes decisions, but the right framework ensures defensible and ethical actions.


About Us:


bigspark’s Financial Crime Practice bridges the gap between people, processes, regulations and technology in Financial Institutions.

We have successfully delivered in multiple Banks and FIs:

  • Financial Crime advisory, such as regulatory remediation projects and FinCrime target operating models
  • World class Data and Engineering solutions, such as Client Lifecycle Management platforms
  • Strategic technology solutions such as modern AI and ML for Fraud Prevention.

Our people have strong applied experience in FinCrime and Fraud and are insatiably passionate about solving problems the industry is facing.

Jo Whalley

Jo Whalley

FinCrime/Fraud Lead
Shaine Ismail

Shaine Ismail

bigspark Founder
Rayane Houhou

Rayane Houhou

Senior Management Consultant