Building a Global Faculty
Following significant regulatory sanctions, the client, a prominent tier 1 global bank was placed under monitorship with one of the remedial actions instructed being for them to undertake a global financial crime remediation / re-education programme. Given the unique nature of this requirement, coupled with the client having outsourced learning to an external provider a year earlier, a lack of suitably qualified financial crime SME resource existed.
HHI’s Principle Consultant was engaged with an initial objective of scoping a full set of requirements to address this shortfall. Having identified and produced a comprehensive set of performance standards, had them signed off, and been commissioned to deliver the solution, the Principle Consultant and team worked with the client and external learning company’s recruitment function, providing oversight and assurance on global recruitment activities in service of identifying the most appropriately qualified individuals to move to the on-boarding induction programme.
Concurrent to the recruitment activities, and being mindful that no similar global financial crime remediation programme had occurred previously, HHI’s Principle Consultant and team began the construct of a multi faceted global control framework. It was recognised that as there was no precedent for such an undertaking, comprehensive standards for all associated activities needed to be designed, developed, and signed off by the client as falling within their risk appetite before then being implemented. A detailed ‘route to competence’ for external financial crime SME consultant facilitators was constructed, and associated policies and procedures created, and an overarching Training and Competence (TC) scheme and regime designed and developed.
Once the control framework had been developed, presented, and signed off by the client, design attentions turned to the construct of a ‘train the trainer’ programme. Recognising the unique requirements of candidates needing to be subject matter experts in financial crime, but also capable of demonstrating professional facilitation skills, a robust continuous development programme was built underpinned by the principle of ‘show not tell’. The purpose of this approach was to ensure that, as external resource, the SME Consultants had the bank’s internal delivery and conduct standards demonstrated to them, were provided time to develop themselves to the demonstrated standards, received performance coaching to close any development gaps, and given plenty of practice opportunities before any formal assessments were undertaken. The positive outcome of this methodology was the successful on-boarding globally of circa 100 financial crime SME consultant facilitators who now make up the ‘global faculty’.
Importantly, the global faculty team was made up of industry practitioners (not theorists). Each member of that team had complimentary skill sets, which ensured coverage of key competencies from operational risk to stakeholder management, trainer selection to supervision. The team developed a governance framework in partnership with the Bank, which was devised in order to provide global controls and bank-wide consistency
The faculty team were, and are dedicated to the delivery and embedding of financial crime training. They were/are self sufficient and agile, but totally connected to the business in terms of stakeholder management and sponsorship. Increasingly, we found senior management education was paramount, in order to ensure that employees embraced the training and utilised it in their daily role. This was not a tick-box exercise. Whilst much was known about financial crime in the Bank, very few understood how this needed to be trained in order to meet the Bank’s commitments, and who was actually competent to undertake this task.
The team wanted to make sure that the first line of defence were trained by experts who could relate to both their role and the real issues they face. The team set about developing a performance development programme and undertook robust induction exercises for the trainers to ensure the faculty was both knowledgeable and well equipped to execute the training. Evidencing facilitator competence was an essential element brought to the client by the faculty team.
In addition to competent facilitators, the team invested in supervision to ensure that the knowledge and skills of all global faculty members remained up to date and consistent. Twenty four hour support was provided across the globe to ensure that any issues were dealt with ‘real-time’ and regular checks on facilitators skills and knowledge was conducted.
HHI’s Principle Consultant lined directly to the accountable person for this project and as a result was fully aware of their need to be assured that we could attest to the competence of the facilitators to both the externally appointed monitor and regulator. The faculty team provided that reassurance.
