implementing robust aml/cft monitoring solutions
TRANSCRIPT
AML/CFT Technology Solutions
Implementing robust, effective and efficient AML/CFT Monitoring Solutions
Francois Combrinck
29% of Technology Projects are Successful:Delivered on time, within budget, within scope,
realized value and satisfied stakeholders*
* Source: Standish Group Chaos Report 2015
19% of Technology Projects are outright failures and failed to meet any success criteria
29% Success
19% Fail
52% of Technology Projects meet only some success criteria
52% Challenged
58% of Small projects using an Agile methodology are successful.
Collaboration
• Executive Sponsorship
• Emotional Maturity• User Involvement
Process
• Optimisation• Standard
Architecture• Agile Process• Modest Execution
Expertise
• Skilled Resources• Project Management
Expertise• Clear Business
Objectives
• Individuals and Interactions over processes and tools
• Working software over comprehensive documentation
• Customer Collaboration over contract negotiation
• Responding to change over following a plan
Source: agilemanifesto.org
• Increased Revenue• Reduced Speed to Market• Increased Quality• Increased Visibility• Improved Risk
Management• Greater Flexibility• Greater Cost Control• More Engagement• Increased Customer
Satisfaction• Right Product
Source: allaboutagile.com
What is Agile?
Analysis
Design
BuildTest
Implement
Analysis
Design
BuildTest
Implement
Coverage• Products Coverage• Systems Coverage
Risk• Product Rules• Money Laundering
Risks
Compliance
• Internal Policies• National Legislation• International Best
Practice and Standards
Quality requirements are
Source: A Guide to the Business Analysis Body of Knowledge Version 3.o
Analysis
Design
BuildTest
Implement
“A useful representation of a need”
Solution Agnostic
Testable
Clear and Unambiguous
Complete
Consistent
Prioritized
Data Considerations Technology
Process
Data Monitoring Universe
Control
Cloud
Most Appropriate Source
Transformations from system of record to monitoring
Understanding the risk introduced by each transformation
Completeness of data
Technology ConsiderationsTechnology
Process
Data Monitoring Universe
Control
Cloud
Most Appropriate Solution or Solutions
Size vs. Sophistication
Market Leader or Startup
The Myth of the Tactical Solution
Process ConsiderationsTechnology
Process
Data Monitoring Universe
Control
Cloud
Integral to Overall Solution
Analysis Processes for Efficient Analysis and Effective Reporting
Control Processes to Ensure Effectiveness and Efficiency of Monitoring
Change Processes
Solution ControlsTechnology
Process
Data Monitoring Universe
Control
Cloud
Operational Controls for Effectiveness
Controls that monitor data completeness
Controls that monitor process execution
Operational Controls for Efficiency
Controls that monitor back-end and front-end stability
Controls that monitor quality of alerting
Controls that monitor quality of alert analysis
Controls that monitor quality of reporting
Solution Residency ConsiderationsTechnology
Process
Data Monitoring Universe
Control
Cloud
Multi-Jurisdictional Monitoring Solutions
Desired Level of Control
Desired Level of Oversight
Data Privacy
Cloud
Cloud Computing OptionsTechnology
Process
Data Monitoring Universe
Control
Cloud
Solution Hosted On-Site (No Cloud)
Infrastructure as a Service (IaaS)
Platform as a Service (PaaS)
Software as a Service (SaaS)
Mor
e C
ontr
ol,
Gre
ater
Fix
ed C
ost Less C
ontrol, Less Fixed C
ost
Total MonitoringTechnology
Process
Data Monitoring Universe
Control
Cloud
Customer Screening
Customer Due
Diligence
Data Quality in Customer Lifecycle
Transaction Monitoring
Customer Risk
Assessment
Analysis
Design
BuildTest and Tune
Implement
• Alert Quality• False Positives• Machine
Learning
• Money Laundering Risk
• Coverage
• Systems Processes
• Business Processes
• Completeness• Accuracy• Controls
Testing for Effectiveness
Testing for Efficiency
Tuning for Efficiency
Tuning for Effectiveness
Sources• Standish Group: Chaos Report (2015); Summary extracted from https://www.infoq.com/articles/standish-
chaos-2015 on 3 October 2016.
• Benefits of Agile: Retrieved from allaboutagile.com on 22 October 2016 (http://www.allaboutagile.com/10-good-reasons-to-do-agile-development/)
• The Agile Manifesto: Retrieved from agilemanifesto.org on 22 October 2016
• International Institute of Business Analysis: A Guide to the Business Analysis Body of Knowledge Version 3.0, April 2015.
• Joe Barios: What Every Business Analyst Must Know About Cloud Computing; Retrieved from https://www.joebarrios.com/five-things-business-analyst-know-cloud-computing/ on 23 October 2016.
• PriceWaterhouseCooper: Stress Testing anti-money laundering / counter-terrorist financing frameworks for the securities industry; Retrieved from http://www.pwchk.com/webmedia/doc/636119486865834411_forensic_anti_money_laundering_oct2016.pdf on 2 November 2016
• Keith Furst: How to Conduct an AML System Assessment