Implementation of an AML/ATF Monitoring and
Controlling System
The issue
A transfer agent has decided to rely on technology
to receive support in establishing, maintaining and
optimizing compliance with AML/ATF regulations.
The approach
The implementation of an AML/ATF solution is to be
considered and conducted as a project. We assisted
the Compliance Officer, who acted as project leader,
to set-up the project team and the pilot committee,
to plan and and organize workshops and to conduct
the overall project under the sponsorship of the Top
Management. In particular, we provided assistance
on three areas:
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1. Identification of client needs and
AML tools pre-analysis
The first step was to identify client needs
based on specificities like the transfer agent's
activities, the regulation applicable or the
distribution schemes. The subsequently executed
pre-analysis process covered a wide range of
tools including the following functionalities:
- Transaction monitoring – client segmentation,
scanning and analysing data for potential
money laundering activity;
- Customer risk rating tools;
- Watch list filtering – screening
new accounts, existing customers, beneficiaries
and transaction counterparties against terrorist,
criminal and other blocked-persons watch lists;
- Automation of regulatory reporting, filing
of suspicious activity reports (SARs), currency
transaction reports, or other regulatory reports
with the government; and
- A detailed audit trail to demonstrate compliance
efforts to regulators, as well as respond
to FIUs and other requests
2. Check of data quality
Before best of breed systems can be implemented,
data quality is a vital consideration. Deficiencies
or inconsistencies in existing financial and
KYC data can have large impacts on the effectiveness
and reliability of the information supplied
by even the most advanced AML systems. Our data
management experts helped our client to prepare
and cleanse data to ensure optimum data quality
for the seamless construction of data feeds
and correct manipulation of data during data
model implementation.
3. Design adequate customisation and
operational procedures
We worked closely with the project team and
with the tools providers implementing the systems.
During implementation, we contributed to the
customisation and configuration of risk views
aiming at optimum results (e.g. low rate of
false positive alerts). In addition, we designed
effective operational procedures which define
roles and responsibilities of each actor (Compliance
department, TA officers, IT, etc.).
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The outcome
Our client benefits from an integrated AML/ATF system
to play a key role in:
- Providing access to reliable transaction and
customer data;
- Ensuring data consistency, timeliness and availability
when it is required;
- Monitoring suspicious activity in an accurate,
timely and effective manner;
- Assisting in the management and reporting of cases
flagged for investigation; and
- Providing management with key AML/ATF management
information on a daily and monthly basis
