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?

Risk

CoverageCompliance

Governance

Analysis

Design

BuildTest

Implement

Analysis

Design

BuildTest

Implement

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

Analysis

Design

BuildTest

Implement

Analysis

Design

BuildTest

Implement

Technology

Process

Data Complete Monitoring

Control

Residency

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

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

Greater Control

Less Risk

Innovative Monitoring

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