This issue related to a client who executed a Foreign Exchange Spot deal (Buy USD 8, 252, 565/Sell IDR 120, 569, 986, 338) in 2020 by using the list of invoices as the underlying document. A client has the privilege to submit only the list of invoices at the latest on Spot’s value date. Besides, they responsible for administrating actual invoices when requested by the Bank.
Firstly, I am responsible for performing a random sampling of the list of invoices and requiring actual invoices for the upcoming month as a control process. When I chose this client as a sample, I found mismatch data between a list of invoices and actual invoices as well as duplicate invoices. Secondly, I found that most of all the invoices already paid before Spot’s value date. As a result, the Bank was at risk fined 1% of the deal or a maximum IDR 1 billion from the regulator.
To solve this issue, I led a Financial Markets Operation Team consisting of 5 people to communicate with the client to provide the appropriate underlying document. After further investigation, the root cause was a knowledge gap due to a client’s Treasury Team who provided invoices based in India. Hence, I took the initiative to work together with the team to educate the client and create a mini-guideline that summarizes Indonesia’s regulatory requirements. I also collaborated with the Relationship Manager Team to require them to revise the document. Furthermore, I proposed to the Compliance Team as a Risk Owner to reform the control process where clients who used a list of invoices must provide actual invoices at least on the Spot’s value date. Otherwise, the client’s deal will be unexecuted.
Finally, my proposed action plan has been approved by the Compliance Team. I have successfully changed the existing control process and helped the Bank to mitigate the risk exposure. Also, after we educated the client, they have shown a clear understanding and complied with local regulatory requirements on the next transaction.
This issue related to a
client
who executed a Foreign Exchange
Spot
deal (
Buy
USD 8, 252, 565/Sell IDR 120, 569, 986, 338) in 2020 by using the
list
of invoices as the underlying document. A
client
has the privilege to submit
only
the
list
of invoices at the latest on
Spot’s
value date.
Besides
, they responsible for administrating
actual
invoices when requested by the Bank.
Firstly
, I am responsible for performing a random sampling of the
list
of invoices and requiring
actual
invoices for the upcoming month as a control process. When I chose this
client
as a sample, I found mismatch data between a
list
of invoices and
actual
invoices
as well
as duplicate invoices.
Secondly
, I found that most of all the invoices already paid
before
Spot’s
value date.
As a result
, the Bank was at
risk
fined 1% of the deal or a maximum IDR 1 billion from the regulator.
To solve this issue, I led a Financial Markets Operation
Team
consisting of 5
people
to communicate with the
client
to provide the appropriate underlying document. After
further
investigation, the root cause was a knowledge gap due to a
client’s
Treasury
Team
who provided invoices based in India.
Hence
, I took the initiative to work together with the
team
to educate the
client
and create a mini-guideline that summarizes Indonesia’s regulatory requirements. I
also
collaborated with the Relationship Manager
Team
to require them to revise the document.
Furthermore
, I proposed to the Compliance
Team
as a
Risk
Owner to reform the control process where
clients
who
used
a
list
of invoices
must
provide
actual
invoices at least on the
Spot’s
value date.
Otherwise
, the
client’s
deal will be
unexecuted
.
Finally
, my proposed action plan has
been approved
by the Compliance
Team
. I have
successfully
changed
the existing control process and
helped
the Bank to mitigate the
risk
exposure.
Also
, after we educated the
client
, they have shown a
clear
understanding and complied with local regulatory requirements on the
next
transaction.