1. ©LogicaCMG plc 2005 1 Making Compliance Pay Ian Larkin Head of Risk and Compliance LogicaCMG UK IBA Seminar 22nd October 2005

2. ©LogicaCMG plc 2005 2 Regulatory Compliance The harsh reality is: Cost of regulation is huge –Implementation, then operation & maintenance –£200m for a Tier 1 bank, £1bn in 2005 for B2 across Europe Aim for minimum acceptable compliance –Minimizing spend, cutting scope Regulatory programmes are “siloed”, despite overlaps –Minimizing the project dependencies –Little coordination, few synergies, multiple hits Compliance causes business and strategic disruption –Delays strategic business programmes –Impacts business as usual Is a rubber stamp the only benefit?

3. ©LogicaCMG plc 2005 3 An Alternative Strategy Regulatory compliance is not just an overhead - it should add value! so… Don’t do it because the regulator says so; do it for business benefit, and comply “en passant”.

4. ©LogicaCMG plc 2005 4 Two ends of a spectrum –Disparate projects to cost, implement & manage –No strategic overview –“Do what we must” –Back-pressure –Repetition of work –Resource intensive –Co-ordinated strategic approach –“Compulsory spend – use it wisely” –Business gain costs less! –Progressive, incremental development –Optimal economic capital allocation Minimum compliance Benefit-based

5. ©LogicaCMG plc 2005 5 Some quotes Woolly or wise? –“We don’t want MI to provide information internally – only to send reports to satisfy the regulator!” –“We are not spending anything on Basel II! We are enhancing our Credit Risk system, which will be Basel compliant.” (Tier 1 Head of Risk) –“We see B2 as giving us the opportunity to develop risk- based pricing for our retail customers.” –"Spending on Sarbanes-Oxley is an upfront investment in making the processes of the company better," says BP’s Macdonald. "We don’t view it as an intolerable burden.”

6. ©LogicaCMG plc 2005 6 How to get some benefit… Re-use information & systems –Sox process maps  B2 OpRisk –AML analysis  CRM –Stress testing  risk navigation Use aggregated information –Counterparty exposure  limit utilisation, sales authorisation –Shared statistics  model calibration, benchmarking Use consistent metrics –Enterprise Compliance Data Management –Comparative risk measures  risk-adjusted returns –Finance & Risk Integration

7. ©LogicaCMG plc 2005 7 Business Issues in AML Anti-Money Laundering Claim Fraud Employee Fraud Financial Crime A multi faceted beast… Identity Fraud Trader Fraud Corporate Fraud Manage high volume of alerts from detection systems Prove that the organisation is following the correct processes Investigate crime holistically across the organisation Investigation and Case Management Use case data proactively to protect the organisation Conduct processes more efficiently and reduce workload

8. ©LogicaCMG plc 2005 8 financial crime money laundering criminals using FIs to make dirty money clean by placement, layering and integration fraud identity theft, ATM fraud, counterfeit cards, cheque kiting, credit-card fraud, skimming market abuse late trading, market timing, front running parking investments, employee fraud theft of cheques, misappropriation of funds, removing money from customer accounts Take a Proactive Holistic Approach to fight the Growing Threat of Financial Crime Financial crime is more than AML

9. ©LogicaCMG plc 2005 9 What is a Holistic Approach? Stovepipe Solutions AML Market Abuse Corruption Combines Multiple Functions and Crime Areas Holistic Solution KYC Anti- Phishing Check Fraud Card Fraud Identity Fraud Reporting

10. ©LogicaCMG plc 2005 10 With a unified, holistic approach, financial institutions benefit from: increased operational efficiencies and optimized processes reduced costs increased profitability maximized revenues (fraud) greater business insight into risk Combining Crime Areas Directly Impacts Your Bottom Line The value of a Holistic Approach

11. ©LogicaCMG plc 2005 11 Range of solutions Cost Transaction and Customer Watch List Filtering Rules based systems Behaviour Detection Solutions Data Integrity and Acquisition Complexity Know Your Customer’s Business Know Your Customer By Name Customer Due Diligence

12. ©LogicaCMG plc 2005 12 Detection Techniques Profiling Neural Networks Text Mining Decision Tree Outlier Detection Link Analysis Sequence Matcher Rule Patterns

13. ©LogicaCMG plc 2005 13 ATMcashInternetforeign bankswires Rules Engines Good news: Simple to implement, simple to understand, does not require historical data Bad news: Can not detect unknown activity, may miss high risk or ML activity if too narrowly written, or if written too broadly, will increase number of false positives Only Known Scenarios Can Be Detected Leaving New Schemes to Go Unnoticed Rule-Based Detection

14. ©LogicaCMG plc 2005 14 Many Detection Techniques Profiling Link Analysis Finds entities that are linked by common transactions,either directly or at a distance. Can also find entities that appear unrelated but have matching account details. In some systems, link analysis will be used to trigger alerts. In others, link analysis can only be used to investigate an entity that is already alerted. Individuals in terrorist cells often have common addresses, KYC id, phone numbers etc. Profiles of entities are dynamically created based on account activity over time. Used to detect deviations from historical or peer group behaviour. Simpler systems profile only on summarised and discrete account data,e.g. end of day balance. More advanced systems create a statistical fingerprint of multiple account data. The speed of adapting the profile may be linked to the look back period. A shorter look back would result in the profile adapting quicker. Some systems differentiate between Profiles and Outlier Detection. Profiles relate to a customer’s normal behaviour. Outlier Detection relates to activity against Peer Group. Anticipatory profiles require information about how the customer is expected to behave, e.g. max withdrawals, average assets etc.

15. ©LogicaCMG plc 2005 15 Detection Techniques A network of nodes that are organised into layers. The input layer reads values of data attributes and the output layer identifies the class of risk and risk score. After the network has been trained with defined input data and expected results it can be used to classify new inputs into predefined classes. The drawbacks are lack of transparency into why decisions were made and the need to retrain the network as business and risks change. Used for complex, time-dependent problems and when data is received in a series over time. Sequence Matcher Neural Networks

16. ©LogicaCMG plc 2005 16 ATMcashInternetforeign bankswires A Combined / Hybrid Approach A combined approach that includes filtering, profiling, rules and link analysis will deliver the best results, with the fewest false positives, and greatest chance of finding fraudsters and money launderers A Combined Approach Delivers the Greatest Detection Accuracy and Results The best approach

17. ©LogicaCMG plc 2005 17 DETECTINVESTIGATETRACKREPORT TRANSACTION DATA ALERTS INVESTIGATION TOOLS SUSPICIOUS CASE MANAGEMENT INCIDENTS NOT SUSPICIOUS REGULATORY REPORTS ACCOUNT DATA CUSTOMER DATA (NEGATIVE) LISTS MANAGEMENT REPORTS NetEconomy ERASE ! REPORT MANAGER SUSPICIOUS AUTOMATIC INVESTIGATE RISK VIEWS

18. ©LogicaCMG plc 2005 18 5 Elements of Best Practice Integrated & Comprehensive Framework Strategy Organisation & People SystemsOperations Risk Measurement, Reporting and Control

19. ©LogicaCMG plc 2005 19 Ingredients for success Create a compliance culture in the organisation Due diligence in customer identification Know your customers’ financial behaviour and status Set the right objectives for automated systems Establish a comprehensive and integrated risk framework

20. ©LogicaCMG plc 2005 20 Then Make Compliance Pay Work your enterprise compliance data Re-use compliance systems for business benefit Implement economic measures of performance Work towards maximizing the value of the enterprise Ian N. Larkin Head of Risk & Compliance LogicaCMG UK ian.larkin@logicacmg.com direct +44 (0)20 7446 5150 mobile +44 (0)7802 462 067

21. ©LogicaCMG plc 2005 21 Who are we? Logica cm… who? LogicaCMG has implemented RTGS for RBI, nation-wide LogicaCMG is a major international force in IT services to clients across diverse markets We provide management and IT consultancy, systems integration and outsourcing services Formed in December 2002, through the merger of Logica and CMG, the company employs around 20,000 staff in offices across 34 countries

22. ©LogicaCMG plc 2005 22 Fighting Financial Crime Our watch-list filtering system is used by 8 of the world’s largest 20 banks to scan international payments. It also scans half of the world’s foreign exchange payments every day. Implementing ABN Amro’s AML system, covering all of ABN’s banking operations in 66 countries. Assisting Barclays Capital implement its AML and Trading Compliance system globally. Developed the Fraud Investigation system for CIFAS, the UK’s Retail Credit Fraud Prevention Service. Delivered investigation and case management systems for the UK Serious Fraud Office, UK Passport Office, and Crown Prosecution Service in England and Wales. Delivered more than 70 card infrastructure systems since 1984. Driving standardisation and exploitation of smart card and chip card technology including establishing national systems for two countries.

23. ©LogicaCMG plc 2005 23 AML - some of our clients 8

24. ©LogicaCMG plc 2005 24 ABN Amro: Global Rollout All Banking Units – LogicaCMG and Mantas Client Hub Locations Singapore Surveillance Team (Wholesale & Retail) European Surveillance Team (Wholesale and Retail) LatAm Surveillance Team (Retail Only) Each hub acts independently against a set of standards published by Head Office. Multi - Jurisdiction Multi – Business Unit Multiple Data Sources Centralised Processing, Flexible Routing Cost Effective Hub Installation, 5 Countries at a time. Leverage Resources, Share know how Rapid Time to Market A New Country in 2 Months, ½ Day User Training Region Specific Monitoring, with Transparency for the Regulator Scalable 66 Countries, in 2 years. On Time! On Budget!

25. ©LogicaCMG plc 2005 25 LogicaCMG and NetEconomy Global alliance partners since 2002 LogicaCMG brings extensive experience of assisting banks across the globe with implementing appropriate solutions to manage their business risks and the requirements of international AML legislation. LogicaCMG takes prime contractor responsibility to deliver a system that will meet the regulatory, functional and technical requirements to a committed time and cost. NetEconomy provides class-leading risk management software addressing money laundering, fraud and trade compliance.

26. ©LogicaCMG plc 2005 26 ING Vysya - India –2 Million accounts –5 Million transactions/month IndusInd Bank - India – 2 Million accounts – 5 Million transactions/month AXA Banque - France – 400,000 accounts – 4 Million transactions/month Recent implementations

27. ©LogicaCMG plc 2005 27 Contact… Nath Parameshwaran Business Manager Financial Services - South Asia LogicaCMG Express Tower 3rd Floor Nariman Point Mumbai - 400 021 India Tel +91 (22) 5635 2984 Mob +91 98203 15084 Email nath.parameshwaran@logicacmg.comnath.parameshwaran@logicacmg.com

28. ©LogicaCMG plc 2005 28 LogicaCMG has taken reasonable care to ensure that the information contained herein is correct at the time of publication. Before using or relying on any content in this presentation, independent verification should be obtained. LogicaCMG accepts no liability nor responsibility for any use of or reliance upon the content of this document.