Implementation of compliance processes for discretionary management through a Web Platform

Abstract

This thesis goal is to define and implement compliance processes for a discretionary management web-platform called Birdee. Birdee is a 100% online solution that enables investors to place their money in the online platform. Their money will then be managed on a discretionary basis thanks to algorithms and committees of experts.

Meanwhile, the compliance role is to obey rules and requests made by persons or institutions that have authority power. The compliance in the Birdee online platform scope is three points: the anti-money laundering and counter terrorism financing policy, the onboarding process and the risk management.

In order to carry out the definition and the implementation, a study of the laws, circulars and directives regarding these three points is developed in the thesis. In addition, the Birdee platform’s online feature brings additional requests. Indeed, a web-platform client behaves differently than a client who has a direct relationship with his portfolio manager. This thesis complexity resides in the linkage between the financial sector’s regulator demands and the online client’s demands.

The linkage leads to an online questionnaire creation that will allow Birdee’s client acceptance. This questionnaire follows the demands done by the regulator. It respects MIFID II and the laws that regulate the anti-money laundering and counter financing. It also leads to the anti-money laundering, counter terrorism financing and risk management processes. Those processes respect the laws linked to the anti-money laundering and the risk management.