What is a Four Eyes Check?

A Four Eyes Check, also known as a Quality Assurance (QA) check on investigated alerts, is a commonly used internal control measure, which requires all investigated alerts to be double-checked by a second competent individual, independent of the investigation. Normally, a 100% QA should be conducted but can vary depending on the organisation’s:

• Nature of business
• International presence
• Cross border payment presence
• Number of historical matches

All rationale and related evidence should be documented and checked by the QA investigator to ensure the correct decision has been made and can be signed off.

Why should an organisation adopt a Four Eyes Check?

Implementing a Four Eyes Check approach to alert screening can help organisations meet their regulatory requirements and ensure a compliance breach does not occur.  

The implications of not having a QA check in place can have negative consequences, which could see the business in question ultimately cease trading. A regulatory breach could mean:

• Substantial, unaffordable fines for organisations and individuals
• Irreparable reputational damage
• Suspension from trading or the revoking of a banking licence to financial institutions

True alert outcomes can provide senior management with a view on, whether:

• Internal processes and procedures are correctly understood and implemented
• Workflow conforms to regulatory standards
• Investigators have understood or misunderstood the procedure content
• BAU output is of the appropriate quality or requires improvement
• Further investigator training is needed.

Depending on an organisation’s appetite for risk, best practice states that assurance activities should take place to ensure that all investigated alerts meet quality standards.

What are the benefits of conducting a Four Eyes Check and how are they achieved?

MI data on alert investigation in conjunction with an organisation’s compliance framework can ensure high-quality standards and adherence to regulatory compliance.                

Organisations should be able to produce adequate MI on alert queues for senior management and ensure internal processes and procedures are appropriately documented.

Training all employees on processes and procedures is key, as is ensuring that company policy is understood, deployed effectively and is subject to consistent and regular review.

A constant review of the output data achieved from the investigation and QA processes is imperative to ensure:

• The correct productivity and quality figures are being achieved daily
• Seasonal alert spikes are identified and strategies implemented to deal with them
• Identification of training for underperforming investigators
• Completion dates on alert queues using historical data
• Regulatory requirements are met, and safeguards are implemented.

Implementing a risk team to constantly monitor new and emerging risk as well as dissecting new legislation will ensure an organisation stays ahead of the curve.  

Establishing and identifying shortfalls in the compliance framework is key to a successful compliance programme.

SQA Consulting can help identify and implement strategies to ensure regulatory compliance is achieved for more information Contact us.

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