Getting Started 

After working with HOPE International (“HOPE”), Urwego Bank’s (“Urwego”) shareholder, on a global strategy review and operational assessment, Varvellium was subsequently engaged to provide industry expertise consultancy and programme governance to HOPE for its global Anti Money Laundering (“AML”) readiness programme, beginning in Urwego. 

The Need

Urwego, a regulated bank in Rwanda, had been given instruction by the National Bank of Rwanda to have appropriate AML governance, surveillance automation and operational frameworks in place to manage and report on AML implications on their business. These framework solutions needed to be in place in order to be fully compliant to meet an agreed regulatory deadline. 

These requirements were a significant delivery for the Board and Management of Urwego, had global stakeholder focus and included potential regulatory sanctions and fines for non-compliance. The management and Board of Urwego appropriately prioritised this programme delivery as their top priority project. 

Varvellium was able to leverage its experience in the financial services industry, and specific knowledge of the microfinance industry (with in depth knowledge of regulatory requirements, African marketplace realities and operational eco-system dynamics). Specific deliverables included:

·       identification, appointment, and implementation of a suitable automated solution;

·      development, documentation, and implementation of a local / global AML policy;

·       review and update of operational processes;

·       comprehensive training of AML concepts and practices across the entire organisation (Field to Board); and

·       reporting and escalation practices.

Addressing these requirements could have been overwhelming for Urwego given the implications of these changes, and the need to understand and embrace local regulatory requirements beyond current understanding.  At the time, of engagement, and in common with many other institutions, AML reporting was manual in nature, time-consuming, open to error. Urwego and HOPE management were extremely clear that they wanted to turn their process into one that was fully automated end-to-end meeting and where possible exceeding regulatory requirements. 

“We recognised that Urwego had significant needs in order to satisfy the requirements and obligations set upon us by the Central Bank. We knew that we needed practical help and advice on a broad selection of topics and Varvellium was able to meet and exceed all of our expectations”
Alice, Chief Risk and Compliance Officer, Urwego Bank 

The Solution

As experts in the micro finance industry, Varvellium was well placed to assist Urwego in their efforts to address this need. Initiating a formal project management structure, Varvellium engaged local and global stakeholders to frame the various needs. 

Regular engagement and needs analysis determined specific requirements for an automated solution, that allowed Varvellium to go to market and identify 10 potential AML vendors. After a 4-month evaluation process, PIO-Tech, a Jordanian solution provider was chosen by HOPE as their global partner. 

“Our system provides a comprehensive solution for Financial Services entities to meet their regulatory and compliance obligations in an efficient and effective manner. Senior management can be confident that they have the tools implemented to meet current and future needs in the AML sphere”

Murad, Managing Director, PIO-Tech

PIO-Tech and Varvellium implemented the automated solution, including:

·       integration with Urwego’s Core Banking System, Temenos T24; 

·       completed training on the use of the solution including alert management, case review and remediation and reporting requirements; and

·       soft launch / parallel run to ensure user confidence and capability with the system.

“PIO-Tech’s solution looks fantastic and has been easy to adopt into our new framework and processes. The solution is a welcome addition to our AML efforts”

Theopiste Nyarwaya, Head of Compliance, Urwego  

In parallel to the automation delivery, the Project team completed work around:

·       policy and procedure documentation to ensure compliance with regulatory requirements; 

·       operational process evaluations to identify areas of enhancement and development; and 

·       completed training for over 300+ staff members in the specifics of AML, regulatory requirements, roles, and responsibilities etc.

“Varvellium starts by simply listening. We want to ensure we understand the needs of our client and to fully understand their known issues and the potential needs that could arise. We offer our input and advice only after we understand our clients fully. Consultancy, advice, and governance can only succeed once we have built a relationship of trust. It is evident that this approach has worked with Urwego as the project finished on time, on budget and on scope, against a significant delivery requirement from both internal and external stakeholders “

Paul & Tom, Varvellium Partners

Delivery

Banks like Urwego can face challenges in managing significant implementations such as this. Appointment of an experienced consultancy can be of significant benefit to management and staff accordingly.  Initial work completed by Varvellium and Urwego in respect to framing the regulatory environment and their internal needs was extremely helpful to all parties, creating positive leverage points for the project team. 

Sound project management governance, key deliverable timeline management, transparent management structures, coupled with regular progress reporting ensured that all stakeholders were appraised of progress and able to make necessary decisions and course corrections through the life cycle of the project. 

Working with Urwego was incredibly effective; onsite visits and continual engagement with the team developed highly important relationships. This was key when implementation of PIO-Tech solutions required multi-faceted, multi-location and multi-language team environments.

Wherever your organisation is in the determination and implementation of an AML framework and eco-system, Varvellium is well placed to assist in ensuring that requirements are determined, prioritised, and implemented.  

Results

The challenge seemed to be insurmountable for the Urwego team.  Thanks to Urwego’s Compliance, Operational and IT teams, the project was able to move forward addressing significant issues and time constraints. 

Varvellium’s confidence seemed “too good to be true” at the inception of the programme, but results speak for themselves, and we proved our value and provided a highly professional service.  Urwego have been able to meet their regulatory obligations, have removed manual reporting and workaround processes, with tangible headcount and cost benefits, and have a platform for risk evaluation and assessment that puts them in a position of strength. 

Looking to their future, Urwego now has insight and overview of their business and client relationships that they previously did not have. This transparency will provide them with ways to manage and understand their risks and to identify areas of business opportunity and focus. 

The Urwego Management and BoD have been more than satisfied with the results of completing the deliverables on / ahead of deadlines. Numerous recommendation letters are available as reference. 

“ The team at Varvellium have been an excellent resource for us.  We are looking forward to continuing to work with them on our next project and would be happy to recommend them for their excellent service, value for money and professional support. Thanks again for everything you have done” 

Jimmy Rutabingwa , Deputy Chief Executive Officer, Urwego Bank 

Urwego had a problem faced by many Banks and Microfinance institutions but following this successful implementation it enabled them to flush out some of these extra value propositions that weren’t necessarily considered beforehand and were only brough to the forefront as new processes were revealed enabling them to see operational deficiencies and most importantly, the opportunities in their client and transactional data that they couldn't see before. 

Further Engagement

 Building on the success of this work, Varvellium has been further engaged to help Urwego maximise the benefits of this project and to enhance operational processes and reporting capabilities. 

In addition, HOPE have engaged Varvellium to implement the same AML framework to other global institutions in its organisation.