Transcript Document
Global GIFTS Integrated S o f t w a r e I n c. Funds transfer & Telecommunications Systems Selecting & Implementing an AML Solution Paul C. Gdanski Tel: (646) 865-1301 ext 240 Email: [email protected] Web site: www.giftssoft.com 7/21/2015 1 Today’s Situation • • Continuous pressure by regulators / examiners Despite improvements made by financial institutions, the compliance bar keeps rising and regulator expectations are high • Many institutions still addressing requirements in a manual or semi-automated non-cost effective manner • Existing software solution may no longer be adequate • Limited number of staff due to economic climate • Limited dollars due to budget cut backs • With large volumes of transactions being processed daily how do you perform effective monitoring? • How do you adequately document and evidence your investigative and due diligence processes? 7/21/2015 GIFTS S o f t w a r e I n c. 2 Benefits of an automated AML solution • • • • • • • • • • Data warehouse of all transactional & CIF data Maintain transaction history online for 5 years or longer Library of detection scenarios delivered with solution Ability to easily modify existing detection scenarios Ability to easily create additional detection scenarios Ability to assign / calculate risk weights for customers, accounts, and transaction types Reduce time normally associated with monitoring for unusual transactional and account/customer activity Reduce time associated with responding to regulatory agency subpoenas & law enforcement inquiries Detailed transaction drill down capability Ability to systematically pair / join similar names 7/21/2015 GIFTS S o f t w a r e I n c. 3 Benefits of an automated AML solution • • • • • • • • Wire transaction analysis by country Electronic case management & work flow Systematic generation & tracking of SAR & CTR forms Comprehensive Customer Information File to assist with CIP and KYC Requirements Support imaging integration Data export facility for use in other applications Automated list filtering process (e.g., FinCEN 314(a). PEP, OFAC, internal) Ability to leverage AML solution data for fraud monitoring and other purposes 7/21/2015 GIFTS S o f t w a r e I n c. 4 Re-evaluating Existing Software • • • • • • • • How many years has existing solution been in place? Does existing software adequately address current monitoring requirements, including new products & services, increased transactional volumes and increased customer growth? Does existing software address most recent regulatory requirements? Has your regulatory examiner, internal or external auditor identified any deficiencies in the current software? Does vendor still provide product updates? Is it the same vendor you purchased software from? Make a point of looking at other available solutions for comparison Replace if necessary 7/21/2015 GIFTS S o f t w a r e I n c. 5 Steps to a Successful Implementation • • • • • • • • • • • Identify, allocate & dedicate required resources to the project Technology & Business partners should work closely together before, during, and post implementation Business requirements (functionality) should be defined by all potential users of the solution Build vs. Buy? What is in the Budget? Is there a Platform preference? Is there a database preference? Define all data sources Determine quality of data - garbage in equals garbage out Define how solution will be deployed Narrow selection to three vendors 7/21/2015 GIFTS S o f t w a r e I n c. 6 Steps to a Successful Implementation • • • • • • • Speak to other institutions that are using the solutions (Technical & Business) What type / level of training is available from the vendor? How well is the user documentation written? What type of support is provided? Ensure that mandatory changes, such as SAR, CTR, SWIFT, Fed and CHIPS changes are included as part of maintenance agreement Ensure that generic product upgrades are part of the annual maintenance agreement – release notes, updated user guide, training What level of post implementation vendor support will you receive? 7/21/2015 GIFTS S o f t w a r e I n c. 7 Steps to a Successful Implementation • • • • • • • • • Is there an active User Group? Is the recommended hardware / servers sized correctly? Perform comprehensive User Acceptance Testing Tune detection scenarios during UAT Is there adequate staffing to review alerts? Do written procedures reflect the new automated environment? If necessary, modify existing workflows and / or procedures Don’t allow the system to get stale – review detection scenarios periodically (e.g. every 6 to 12 months) Use the system 7/21/2015 GIFTS S o f t w a r e I n c. 8 Sample Detection Scenarios • Wire Transfers involving high risk geographies, such as known drug producing and/or drug transport countries • Multiple wires to a single beneficiary or single address • Multiple wires from a single originator or single address • Originator to Beneficiary Pair in wire transfers • Wire transfers routed through multiple geographies / jurisdictions • Cash Deposits followed shortly thereafter by outgoing wire(s) • Inbound wire(s) followed shortly thereafter by cash withdrawals • Pre-payment of loan proceeds • Accelerated payment of loan proceeds 7/21/2015 GIFTS S o f t w a r e I n c. 9 Sample Detection Scenarios • • • • • PUPID – Pay Upon Proper Identification Large incoming wire to a dormant account followed by cash withdrawals that deplete the balance in the account Deposits (cash or otherwise) that exceed the reported income level of customer The deposit of cash in amounts that consistently fall just below reporting requirements Structuring 7/21/2015 GIFTS S o f t w a r e I n c. 10 Thank you! Paul C. Gdanski Vice President, Sales Tel: (646) 865-1301 ext 240 Email: [email protected] Web Site: www.giftssoft.com 7/21/2015 GIFTS S o f t w a r e I n c. 11