Anti Money Laundering, Data Collection and Reporting Information Technology Service External Systems Unit Global Programme against Money Laundering
Money Laundering/Terrorist Financing – The Worlds Response Establish a global environment hostile to money laundering and terrorist financing Implement international standards including the FATF 40+9 recommendations Establish Financial Intelligence Units around the world Establish protocols and platforms for sharing intelligence and evidence Secure technical assistance for countries to implement international standards Uniform and standard AML platform - desirable
Anti-Money Laundering Process Three essential components of an AML/CFT regime: A functional compliance culture Functional regulatory bodies – central Bank, SEC, Insurance Regulator etc An effective financial intelligence unit tasked with: The above processes ideally should be automated particularly if they involve high data volumes
Designed as a modular system to fit the needs of any FIU irrespective of size from a single computer with a few thousand processes - up to 500 million processes over 5 year period irrespective of file size Processes and analyzes reports on: - Suspicious transactions - Financial transactions – of any type - List or alert based reports – CFT etc Fully electronic data collection and dissemination from any source such tax, law enforcement records, immigration service (passenger movement records), property registrar, vehicle registrar etc…. goAML – global Operations Anti-Money Laundering
Data Collection Data Clean up Ad-hoc queries and matching Statistical reports on reports received and processed Structured analysis (strategic and tactical) Profiling Rule based analysis Workflow System Task Assignment and Tracking Document Management (full text search) Intelligence file management system Integration and/or data acquisition from other sources Charting and diagramming Intelligence report writer
goAML – Collecting and Managing Information Reporting standard defined: XML based (world standard format) Samples available for FI IT Personnel Exhaustive documentation available Validation application: Checks for valid XML All required fields are present Data types are correct Ensures reporting entities report in the correct format from day 1
goAML – Gathering and Managing Information Secure website (SSL 512 bit encryption) for: Creating reporting entities - by the FIU Creating contacts Changing contact details - by the reporting entity Report upload Report data entry - manually if necessary Report verification - clean up by system
goAML – Gathering and Managing Information Report History - what reported - accepted/rejected ref number View uploaded report - Individually Submission status - accepted/rejected Common content for any reporting entity - flexible - secure information from FIU - compliance circulars - alerts - name lists
goAML – High Volume Analysis Support analytical and investigation teams with highly sophisticated reporting capabilities. Visualize large volumes of data to help understand the big picture. Monitor potentially suspicious accounts. Reveal patterns and hidden connections. Create analytical charts manually or automatically.
Workflow for STR analysis Tasks and the process diagram are defined by the FIU users - can change to suit their own needs - full visual designer Task assignment and tracking - within FIU - push or pull reports by e-mail Integrated reporting - workflow reports - assignments - progress - results goAML – Collecting, Managing and Analyzing Information
Integrated source tracking - tracks externally sourced information - creates bring-ups, reminders etc Automatic resource scheduling - automatically assigns tasks - monitors workloads - measures outputs/performance Case feedback integration - Produces standardized feedback - reports as word documents goAML – Collecting, Managing and Analyzing Information
Customizable data gathering templates - standardized format for receipt of information from outside agencies that decides transmission medium (email/fax/post) Time in flight analysis - Time management measure goAML – Collecting, Managing and Analyzing Information
Common user interface across analysis screens - screens look and feel the same - supports multiple languages Workspace based (keep information through different reporting sessions) - two work spaces available at any one time - previous work automatically saved - supports text, tables, merged tables, pictures goAML – Analysis and Targeting Solution
Analyst can retrieve, filter and re-arrange the data accordingly to his/her needs. - Rearrange data fields - Change grouping - Filter data - Change data sorting - Save layout - Export goAML – Analysis and Targeting Solution
Linking to other screens from current screen Allows easy comparison of different accounts, persons or entities Each window acts independent of others Copy fields or rows Makes analysis easy Very easy to learn All these components have restricted access goAML – Analysis and Targeting Solution
goAML – Analysis Trails Link charts association charts – transaction flow charts etc Money and person trails for inbound and outbound transactions Trail for duplicated addresses, phone numbers and other identification data Displays: - source and destination displayed as nodes - direction and amount displayed as arrows
goAML – Analysis - Pivots Reports offer many different views of data under analysis Allows for dynamic user filtering and grouping of related data Allows for searching for TOP targets - 5/10/50 etc Flexible data search capability Simple integration with Excel - excellent for net worth analysis - ease of attachment to intel reports - arrives live so can be manipulated by receiver
goAML – Analysis - Intersect Combines data from two different reports - User chooses the two reports populated with data and the columns to intersect Result is displayed in a completely new window with the intersected data
goAML – Information Dissemination Suspicious activity detected Open a new case – analysis output attached goCASE picks this up Export case to MS-WinWord - Case file remains with FIU - Output in the form of Intel report - Sanitised to the level required by the user
goAML - User and role based functions Management: Is able to check the submissions and the status of reporting entities. - performance measure/compliance Analyst: Responsible of conducting the analysis, finding suspicious activities and linking to similar-patterned cases where they exist - analysis Administrator: Allowed to add new user, give/revoke access to screens and different actions. Access to certain actions is dependant on the users role!
goAML - Security Username and password required to access applications. Access can be granted and revoked per: - User - Screen - Certain actions like copy, export etc. Access to screens and data is logged. Data partially encrypted in the database. - Encryption level and extent at the discretion of the user
goAML - Security Access to the system generally or to any part of it at the discretion of the user – the user must open the gate UNODC does not hold private key – cannot decipher encrypted data Rule engine secure Database and system tools installed on the users premises, UNODC has no independent access
Impossible is not a fact, only an opinion Thank you!