READ
People Risk & Compliance

Three cultures, one complex KYC migration project

Date:February 22, 2024

In this interview, Projective Group consultant Rossella Nocera talks about the challenges that come with a multicultural regulatory project. “Luckily, I’ve lived in different countries growing up and this taught me how to bridge cultural differences and find a compromise that would suit everybody around the table. This is the basis of facilitation.” Rossella says.

Hi Rossella, before we dive in: can you tell us about your educational and work background?

Rossella Nocera: “After graduating with a bachelor in International Finance in Italy, I moved to Belgium to complete my master’s degree in business engineering. At the same time, I started my career at the Bank of New York Mellon. I initially had a role in trading, and then I moved to BNP Paribas, still on the trading floor. There I started to contribute to regulatory projects and that really stirred an interest of mine, so I decided to switch to a consulting role. After some years in consulting, a former colleague told me about Projective Group. So I made the move and I never looked back. I’ve been with Projective Group for five years now and I’m very happy!”

The goal is to onboard all the clients from Milan to the Amsterdam HQ, which also implies KYC duties to be carried out.

That’s wonderful to hear. Can you tell us a bit about the project you’re currently working on?

R.N.: “I’m currently working on a big KYC migration project for a large Japanese bank.. Following their announcement of clients and related assets migration to the EMEA headquarters in Amsterdam, , I joined a cool pool of colleagues in the Netherlands who are in charge to manage this big migration from a KYC perspective.

“We’re starting with the Milan branch as a pilot. The goal is to onboard all the clients from Milan to the Amsterdam HQ, which also implies KYC duties to be carried out. In this case, my role is to manage the project from the front office side and to provide guidance to the local office in terms of client requirements to be consequentially reviewed and approved by our SME’s. This task is not easy from the front office’s perspective, as any request of additional documentation or further questions on the existing one can be perceived as a burden by big corporate clients.   So I’m there to support them.”

Sounds rather complicated. What would you say the biggest challenges are that you’re facing in this project?

R.N.: “The main issues are around cultural differences, both from a soft and a hard point of view. For one, there’s a difference in how the Dutch, Italians and Japanese communicate. The Dutch culture in Amsterdam is very straightforward, but you cannot communicate bluntly in high context cultures like the Japanese or the Italian . There, you have to make sure that you’re saying things the right way and make sure you are not in order to maximise results and foster good collaboration that leads to a successful project. Luckily I have already been involved in another big project in a Japanese bank having to run a remediation in the Italian office and I hope I will be able to put all the lessons I learnt to good use! I am also Italian , which of course helps with the language constraints. It is always easier to build trusted relationships with Italian stakeholders when you  speak their languages.

You have to make sure that you’re saying things the right way and make sure you are not in order to maximise results and foster good collaboration that leads to a successful project.

Also, when it comes to regulatory requirements, we can expect differences from country to country. We might have gaps between Dutch KYC requirements and the Italian ones. Or the documentation might need refreshments or full translations ( Italian is still the main working language even in  Italian multinationals). This means delays might be caused by either insufficient documentation from the Dutch legislative point of view or requests to clients to provide further  documentation in English.

“Last,  time constraints perception differs from one country to another. For example: the Amsterdam headquarters had s sent and official request to the Italian regulator to be authorised to proceed with the onboarding and they were expecting a reply in a very short time span. In Latin countries, public entities such as national banks are known for their lengthy delays. Sending weekly reminders to a regulator might even slow down the process and this causes a lot of frustration everywhere.  I think my team did great choosing to challenge the approach in a humble way, asking questions such as “How can we support you? How can we be in touch? What else do you need to provide your authorisation? “, while keeping the stakeholders accountable and engaged in a gentle way. Eventually we got an agreement and we are really kicking off the core parts of the projects now! Let’s just hope the Italian corporate clients are going to be quicker in reacting.

“I do believe that the Projective Group team can have a major impact all along the value chain, from the front office to the middle office activities and then of course the investigation for KYC itself. There are plenty of things that we can influence: process-wise, finding room for improvement, looking for efficiency gains,… I believe we have the opportunity to  show that we’re there to help, not only with KYC activities but also with providing added value with advice and suggestion to improve their processes.”

What about this project do you enjoy most?

R.N.: “I specialise in Risk and Compliance, but I’ve also always had a kick for projects that implied cultural management. Projects in which I’d have to wear several hats, not only in terms of roles but also in terms of facilitation. Just because you speak the same language as someone, doesn’t mean you’re going to understand each other and find a compromise. And it’s even harder when the stakeholders are from three different cultures.”

I specialise in Risk and Compliance, but I’ve also always had a kick for projects that implied cultural management.

“I was lucky to spend parts of my life in different countries.  As a child, we lived in the United States due to my father’s work.I lived in Spain as a teenager and I relocated to Belgium fourteen years ago. All this caused my personality to find energy and motivation  in helping people from different countries and cultures sit around the table and understand each other with empathy and sense of compromise.. Also, as consultants we can bring an added value in making sure that when we leave, people have learned to communicate and work as a team toward a common goal.”

At Projective Group, I’ve never been made to feel like I have to choose between my career or my family values.

One more question for someone who has been here for five years. Why do you believe Projective Group is a great place to work?

R.N.: “I wouldn’t know where to start! There are so many great things about working for Projective Group. But there is one thing that I’d like to stress, as a mother of three young children. At Projective Group, I’ve never been made to feel like I have to choose between my career or my family values. I’ve always had support,  during the COVID times for example. Or, when a project was getting hard ,different people reached out to me to tell me to keep it up, that I was doing a great job ,but also that I was setting a great example for female colleagues who in a few years’ time might also want start a family. So it makes me feel good to know that I am somehow setting an example for young colleagues to tell them that they do not have to choose – especially at Projective Group.”

Conclusion

Navigating a multicultural regulatory project like onboarding clients from the Italian branch of a Japanese bank into the EMEA headquarters in Amsterdam is no easy feat. Being Italian, having lived in different countries, Rossella Nocera is the perfect person for the job. In this project, she gets to play to her strengths while at the same time running her household with three kids. Thanks to a great group of colleagues and the support from Projective Group, Rossella feels very happy in her career. Inspired by her story? Join our team!

About Projective Group

Established in 2006, Projective Group is a leading Financial Services change specialist.

We are recognised within the industry as a complete solutions provider, partnering with clients in Financial Services to provide resolutions that are both holistic and pragmatic.  We have evolved to become a trusted partner for companies that want to thrive and prosper in an ever-changing Financial Services landscape.