Faisal Ahmed

Faisal is currently heading a niche consulting firm, headquartered in the UAE, having offices in Kuwait, India Hong Kong and UK. He leads a team of 20+ consultants specialising in the areas of Risk Management and Compliance including AML/KYC Remediation and Due Diligence, Investigation and Fraud Risk Management, Performance Improvement and Cost Optimisation, Learning & Development and IT Consulting and Security Services.

In order to explore the MENA market, Faisal took up the role as a Partner & Executive Director with Epsilon Global Consulting in Dubai. Over the past 8 months with the firm, Faisal managed to study the market to understand the potential opportunities, build his network, establish a strong team and refreshed his consulting skills.

At Epsilon, Faisal manages a portfolio of clients including large international and local banks in the GCC region as well as engagements diversified across industries including Telecom, IT, Retail, Trading Companies, Finance and Insurance Companies.

GLOBAL HEAD OF CLIENT DUE DILIGENCE

Faisal performed this London based global role from Dubai. Although Dubai was his home location, he majorly worked from London and Hong Kong during his tenure.

Set up and led the Client Due Diligence (CDD) function for Global Banking and Markets. Faisal was responsible for supporting global client on boarding and the ongoing management and oversight of related due diligence and maintenance activities throughout the full client lifecycle.

Provided leadership to the following verticals within the function: CDD Policy Implementation, CDD Learning and Development, Market initiative - KYC Utility Client Adoption, CDD Strategy and Change, Book of Work Management and Planning, and Client Management Due Diligence.

Managed a team of 300+ staff spread across 18 countries and 3 offshore locations.

Faisal played a key role in fronting the Monitor appointed by the US Regulators. There were 13 work streams under Monitor purview, where Faisal worked closely with the London based Monitor Liaison Group to prepare, plan and front all monitor visits globally. He was also responsible to respond to Monitor recommendations and develop the implementation strategy for the remediation, technology and process recommendations.

Faisal was part of the global Senior Management steering committee for Correspondent Banking Enhanced Due Diligence. He led the programme representing the Business and Operations team and provided senior subject matter input into design, implementation and delivery of Correspondent Banking Enhanced Due Diligence process.

Faisal, along with the Asia Pacific Head of Compliance, represented the Bank at AML/KYC policy and procedure negotiations with the Hong Kong Monetary Authority (HKMA). He successfully engaged with the Regulators to challenge the requirements and amend the interpretations of the HKMA requirements around client due diligence. He spent 12+ weeks in Hong Kong in 2015 to revise the policy, reach agreement with the Regulators, roll it out to 22 countries across Asia and developed an action plan in response to the Regulatory findings and recommendations.

Faisal led 4 key streamlining initiatives for the bank sponsored by the Group COO. He delivered a save of USD 11m spread over 5 years in policy simplification, book of work management and automation, client outreach and centralised due diligence utility approach.

Faisal also managed the KYC.com Client Adoption team. This was an initiative sponsored by HSBC along with 3 other banks - JP Morgan, Citibank and Deutsche Bank where a utility was set up by Markit-Genpact to cater to a single client due diligence for common clients across the 4 banks. Faisal prepared the strategy, worked closely with the other banks and Markit-Genpact to design and execute the programme.

An internal proprietary Client Due Diligence workflow tool, Pandora, was prepared within HSBC and Faisal was part of the steering committee to roll out the system. After using it for 3 years, Faisal was given the responsibility to transition to a more controlled platform where the Client lifecycle tool was being developed by Fenergo. Faisal represented Banking Middle Office in the engagement with Fenergo.

REGIONAL HEAD OF AML KYC SERVICES, MENA

Faisal headed the KYC Services operations function for Middle East & North Africa (MENA). He Managed a team of 24 onshore senior/middle management staff based in 6 countries across MENA and 92 offshore team members in Bangalore and Manila. He designed the team structure, roles and responsibilities, policy and procedures, operational risk and controls framework, production plan and resource mobilisation, robust and controlled management information system and governance structure.

Led KYC Services expansion into 5 countries within MENA. This involved leading a project team tasked with strategic planning and target operating model set up around document life cycle management, data and process governance, quality assurance, MI and reporting and implementing KYC production team.

Fronted a number of internal audits, Monitor visits and Regulatory audits conducted for MENA countries. Represented the Bank at audit planning and closure meetings with the Regulators, particularly UAE Central Bank, Oman Central Bank and Jersey Financial Services Commission (JFSC).

Faisal played an instrumental role in offshoring operations from Egypt to India which involved leading a project team, preparation of the Terms of Reference, chairing the fortnightly governance meetings, migration execution and successful transition. He also supervised the customer and transaction screening process which included both forward and reverse screening of customers, beneficial owners, controllers and associated parties for Sanctions and Politically Exposed Person (PEP) lists. Faisal helped the bank identify efficiencies within the transaction monitoring and screening process.

In addition to his KYC responsibilities and Change Management role, Faisal deputised for the MENA HSBC COO and managed a number of middle office activities including Change Management, FATCA programme for the Region, Mandates team with a team of 20+ staff responsible for payment processing, signature updates, statement requests, corporate client instructions and complaint handling. He was also nominated for the aspiring COO programme within HSBC and was considered for the role of Banking COO for MENA in December 2015 which he declined to take up the Global Head of CDD role.

In October 2014, HSBC developed a niche concept of Network Banks, i.e. SWIFT only RMA connections with other banks. This initiative led to the application of a revised appropriate level of due diligence for this newly identified client type. Faisal initiated discussions with key stakeholders, both within HSBC as well as with the Regulators across the globe. He presented the concept to the Global Group Head of Financial Institutions at HSBC and the Regulators to progress with this concept. Faisal was announced as the Global Head of Network Bank Due Diligence at HSBC and led a team of 70+ staff to design the appropriate level of due diligence and lead the remediation of 10, 000+ clients.

FORENSIC SERVICES, ADVISORY PRACTICE, PWC UK

Faisal managed the US Client Due Diligence Remediation for HSBC in 2012 by setting up a team of 150 people to remediate US corporate and Financial Institutional clients in response to the Deferred Prosecution Agreement (DPA) imposed on the Bank by the US Regulators.

Conducted investigations on behalf of multinational clients and financial services regulators which included transaction reviews, investigation into allegations of asset misappropriation and misconduct and bribery and corruption.

Faisal spearheaded a large Foreign Corrupt Practices Act (FCPA) remediation for one of the top European Engineering company and led a team of 40+ consultants globally to design and develop an Anti-Bribery & Corruption Framework.

Published a white paper on Implications of the UK Bribery Act, 2010 on organisations operating in emerging markets, specifically the BRIC countries.

Project managed the largest Global Economic Crime Survey in 2009 and 2011. The survey focused on financial crime risks across 50+ countries where over 3, 000 C-Suite Executives participated. Faisal led a team of 200+ staff across 54 countries to deliver the project over a period of 9 months.

Faisal supervised an engagement for a large UK Bank which had taken over a Dutch multinational bank and helped the client with the integration process in 2009-10 for their global AML process.

Conducted thematic reviews for UK banks and insurance companies to identify typical issues related to captive and third party offshore units. Faisal’s work was covered by an article in Sunday Times in the UK. Faisal also coached the FSA team responsible for conducting the regulatory review and worked closely with them in terms of assessment of the findings and implementation of the recommendations.

Faisal managed the investigation into the management services of private assets - luxury yachts and private jets owned by one of the richest UK High Net Individuals. Faisal managed the relationship and performed independent investigations and review of their management service companies advising the Group on any fraudulent or inefficiency issues and provided recommendations.

Faisal represented PwC Forensic Services at the firm’s Emerging Market desk. He was a member of the India Steering Committee and worked closely on the firm’s strategy around both inbound and outbound business development. As PwC India reported into the Central Cluster led by the UK firm, Faisal was the UK Forensic contact and lead for PwC India practice and helped grow the practice in India with business development activities from the UK. During his 7+ years at PwC UK, Faisal managed 7 large India based engagements leading the projects with a joint UK and India team.

Faisal has delivered a number of subject matter training on Investigations, AML & Sanctions, Anti Bribery & Corruption, Financial and Cyber Crime. In 2008-09, he engaged with the Financial Services Authority (‘FSA’) and trained the investigators working for the Regulator on AML and Sanctions & Financial Crime risks associated with offshoring. He also presented at multiple forums globally on Emerging Market financial crime risks.

Faisal’s work around Offshore Integrity was covered in Sunday Times in the UK in 2010. (http://www.thesundaytimes.co.uk/sto/public/Appointments/article315344.ece)

Faisal managed one of the largest internal investigations within PwC to ascertain gross negligence versus fraud conducted by the firm’s partners on an audit of an Indian IT Company listed in the US that was found guilty of fraud. This was a PwC UK Forensic led investigation where a member firm was the auditor for the IT Company in India and Faisal managed a team of 30+ PwC investigators and accountants and worked closely with 20+ US lawyers from Wilmer Hale to investigate the matter on behalf of the global firm. He led the team and submitted the report to PCAOB in the US.

FORENSIC SERVICES, ADVISORY PRACTICE, KPMG INDIA

Conducted a number of investigations into allegations of misappropriation of funds and financial irregularities committed by third parties, vendors, employees and organisations.

Led the Special Audit of a Residuary Non-Banking Company (‘RNBC’) under Section 45-N read with Section 45-MA (3) of the Reserve Bank of India (‘RBI’) Act, 1934. The engagement was with respect to investigation into the Company’s financial position as at 31 March 2004 examining the manner in which deposits were being mobilised and commission and other expenses being paid. Review of carrying value of the discretionary investments of the ‘RNBC’ and the contingent liability in respect of claims by the Income Tax Department for which provision was not made.

Investigated a fraud in a finance company to ascertain the details of siphoning of funds and irregularities committed by an employee, including investigating the role of company management, if any, in the diversion of funds from the company.

Conducted Supply chain integrity reviews of child labour and working conditions on behalf of a leading International buying house across various states in India from where it procured products. This involved:
o conducting field visits on a surprise basis
o Taking interviews at the site
o analysing the products manufactured
o Identifying the type of labour employed
o Conducting a Migrant labour study

Produced a white paper on the initiative undertaken by the Government and other private NGO’s to help curb the incidence of child labour and desegregation of communities working in the trades by caste, gender and region. Reported on compliance with laws on child labour, minimum wages, health, safety and environment

Conducted fraud risk assessment across industries as part of SAS99 and internal controls review. Obtained a diversified understanding of the fraud risk profile specific to these sectors and provided recommendations based on the rationalisations and controls existing in the companies - this involved a review of the checks, balances and the strategies in place to prevent and detect future fraud. The industries in scope included:
o Banks
o Non-Banking Financial Institutions
o Insurance companies
o IT Companies
o Travel and Tourism Industry
o Manufacturing and Service Industry Companies.

Conducted Contract compliance reviews in India for an International software development company which involved the identification of compliance issues relating to software licensees’ contractual obligations and recovery of licensing fees owed.

Planned, coordinated, supervised and performed statutory and tax audits of client financial statements for public and private companies. This included financial and fraud due diligence reviews.

Prepared financial statements and footnote disclosures within notes to accounts in accordance with generally accepted accounting principles

Reviewed client internal control procedures in order to assess financial statement and operating risks and provided feedback to client management for process improvement

Performed financial reviews and analysis for due diligence reviews for a BPO in India

Conducted a detailed process validation study for a telecom company and reported on the internal control and business viability of its operations in a particular geographical sector