Regulator-Mandated Customer Identification Project

November 14, 2022

In a meeting with the SEC, a major software company was asked a series of questions about its customers. Which of your customers is state-owned? How do you come to those conclusions? What heightened standard of care do you hold those state-owned customers to once they’ve been identified? At the time, the client was not able to answer any of the SEC’s questions. A WCF executive subsequently devised a methodology to investigate all 1400 of the company’s customers following a defined scope intended to answer the SEC’s questions and provide further information to assist the client in ensuring each customer was well-suited for a commercial relationship and that there weren’t any other historical or ongoing issues that could prove problematic to the client organization. Within 10 days, the team was able to provide a report on all 1400 customers identifying which was a government agency or state-owned company, other issues that could impact their suitability as a customer or may suggest the need for enhanced controls, and a recommended course of action for each customer. The timely completion of the project enabled the customer to have a much more productive dialogue with the SEC in their next meeting and help set a much more positive tone for subsequent discussions.