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Rafal Kozlowski

Banking Transformation Lead

Project Manager

Technology Innovation Lead

IT Delivery Lead

Project Portfolio Manager

AI Implementation Lead

Programme Manager

AI Adoption Lead

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Rafal Kozlowski
Rafal Kozlowski
Rafal Kozlowski
Rafal Kozlowski
Rafal Kozlowski

Banking Transformation Lead

Project Manager

Technology Innovation Lead

IT Delivery Lead

Project Portfolio Manager

AI Implementation Lead

Programme Manager

AI Adoption Lead

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    Anti Money Laundering (AML) Control Framework

    • Customer: Corporate & Private Bank
    Project Executive Summary

    A critical regulatory remediation initiative under FSC Article 19 to address material weaknesses in privileged access governance and third-party service provider oversight by implementing Anti-Money Laundering (AML) Control Framework. The project operated under a CAP-driven (Corrective Action Plan) model, targeting audit finding closure through milestone tracking and a mandatory 90-day Internal Audit validation cycle.

    Role Executive Sumary

    Senior Project & Service Delivery Manager, served as the central delivery owner across 14 unique stakeholder groups, coordinating with the CAP Owner, Key Approver, and the on-site BAO Support resource deployed to a bank in Singapore. Owned all milestone tracking in CAP System and Microsoft Project, authored the new ITSM System template for customer data restoration, updated the Process Control Manual (PCM), and managed Quality Assurance and Internal Audit validation packages through to formal CAP closure.

    Deliverables
    • Spearheaded a high-priority AML regulatory remediation programme for a bank in Taiwan, achieving 100% milestone completion within planned timelines with zero execution delays, by directing the end-to-end implementation of a CAP (Corrective Action Plan)-driven delivery model aligned to FSC Article 19 audit findings.
    • Championed FSC regulatory compliance by authoring a new ITSM System template for customer data restoration and updating the Process Control Manual (PCM) for ban entity outsourcing governance, securing successful closure of primary regulatory findings through Internal Audit validation.
    • Orchestrated the remediation of material privileged access weaknesses, implementing pre-approval protocols for 100% of high-privileged OTP accounts, by directing alignment of approved change requests with administrative activities across management tools and consumer banking systems.
    • Transformed third-party service provider oversight from formalistic to forensic log review, ensuring 100% coverage of privileged roles via system monitoring, by establishing monthly review cycles of 5 abnormal activity samples sustained across 3 – 4 consecutive validation cycles to demonstrate control sustainability.
    • Governed stakeholder alignment across 14 unique stakeholder groups, managing the formal 90-day IA validation cycle and evidence package submission, by maintaining a “Green” project status with zero business impact throughout the full programme lifecycle.
    Tags: AML Caital Markets Compliance Payment Systems Regulatory Risk Management Software Technology
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