Anti-Money Laundering From False Positives to Real Positive with Predictive Modelling & Big Data
The False Positives
“If any financial crimes
compliance people out there have just plugged in a monitoring system and think
that they’re done you’re going to be flooded with alerts without
any context,” warned Bank of America’s Bill Fox .This explains why most banks
have conversion rates that are more like 5-7% .Banks need to go beyond their
monitoring systems so as to see impressive results in terms of efficiency as
they need not hire large numbers of staff to sift through alerts from their
monitoring systems. Hence the need to create an in-house system that compiles formation
from different sources such as its monitoring reports, news reports, alerts
issued by regulators, and far beyond & much more & then turns that feedback into “events,”.
Challenges Ahead;
False positives and very low rate
of conversion reflects the deficiency of the AML set up. Besides the stiff
regulatory fines .The below will tell how soon the current system with a meagre
5 to 7 % conversion rate presently will become defunct;
1. There are more than 5 billion cell phones. By 2020, experts
predict there will be more than 50 billion connected devices. Assuredly,
criminals and criminal organizations will be attracted to this new financial
and communications medium s as to leverage them
2. With M-Payments will come digital value smurfing to probably
replace or at least out do traditional money laundering, “smurfs” which
places small amounts of illicit or dirty money into financial institutions in
ways that do not trigger financial transparency reporting requirements. Dozens
or even hundreds of digital smurfs could then be directed to transfer the value
to accounts controlled by organized crime.
3. Law enforcement will be further challenged by issues such as
venue, jurisdiction and competency. The expertise to systematically track
M-Payments simply does not exist. A lack of physical evidence further
handicaps law enforcement investigations, as there may not be any cash or money
equivalents to monitor or seize. If the conveyor or recipient phone is
destroyed, it may be impossible to reconstruct or determine the information
that was on the phone. Here the mortar branch ceases to exist.
4. Today's trade-based money laundering activity goes beyond
traditional laundering of criminal funds to include terrorist financing and
intentional efforts to circumvent international sanctions, “Criminals turn to
this as it's a classic needle in a haystack — an $18.3 trillion business formed
of a "web of complexity that involves finance, shipping and insurance
interests operating across multiple legal systems, multiple customs procedures,
and multiple languages, using a set of traditional practices and procedures
that in some instances have changed little for centuries . This state of
affairs is exacerbated by a number of factors, especially the lack of data
sharing between customs, tax and legal authorities and a tendency to rely on
AML procedures designed to target cash smuggling and financial system misuse.
5. While key players in terrorist networks may be identified by
the international community as terrorists, many of the lower-level,
tenuously-connected contributors to terrorist networks remain unknown. These
low-level contributors, prompted by group actions which mimic popularized crowd
funding strategies have become another source of financing and physical
resources for ISIL. Social media platforms unintentionally provide an effective
method for terrorist groups and their sympathizers to exploit this technology for terrorist
financing purposes.
6. A symbiosis is developing between organized crime and
terrorist organizations. Sharfuddin Memon, director of a Karachi citizens’
crime watch group, described the motivations behind this activity: “The world
thinks this is about religion, but that’s a mistake. It’s about money and
power. Faith has nothing to do with it.”
The Way Ahead
The new innovations also provide
platforms to criminals as well which the current system will most certainly
will not be able to cope with .So the need to extract and analyze in-house and
external data, both structured and unstructured as the illegal process is all about taking ‘dirty’
money and making it ‘clean’ passing funds through an intricate and
interconnected network of people, places & things and their inherent but otherwise
unseen interconnections. The current approach and the AML solutions which
solely focuses on entity-level (person, business, corporation) or transaction
level risk scores, without viewing them within the context of the greater
network risk score.
At the same time a myriad of
business data exists. Communications and social media are growing
exponentially. Industry calls these massive data bases, “big data."
Concurrently, there have been major advances in data mining and advanced
analytical capabilities that can help organizations derive the “intelligence”
from this vast amount of data. Data warehousing and retrieval are
enhanced by cutting edge technologies that search, mine, analyze, link, and
detect anomalies, suspicious behaviors, and related or interconnected activities
and people.
The good news began in 2009 with
the invention of ‘Spark’ (by UC Berkeley ) which is a powerful open source processing engine built
around speed, ease of use, and sophisticated analytics. Spark is a
general-purpose engine used for many types of data processing. ‘Spark’ comes
packaged with support for ETL, interactive queries (SQL), advanced analytics
(e.g. machine learning) and streaming over large datasets. For loading and
storing data, Spark integrates with many storage systems (e.g. HDFS, Cassandra,
HBase, S3). Spark is also pluggable, with dozens of third party libraries and
storage integrations. Additionally, Spark supports a variety of popular
development languages including Java, Python and Scala.( https://databricks.com/spark/about)
In furthering this crucial piece of
innovation Tresata and Databricks announced this March a real-time, Spark and
Hadoop-powered Anti-Money Laundering solution earlier today. Tresata’s
predictive analytics application TEAK, offering for the first time in the
market an at-scale, real-time AML investigation and resolution engine
leveraging ‘Spark ‘.It is certified to run on Databricks Cloud, Tresata’s TEAK
is breaking new ground and offering Banks, Retailers, Telcos & Regulators
the only quick start, rapidly scalable AML solution.
Hope this is a harbinger of an
era where ‘false positives’ is a term of the past making the regulatory burden
more meaningful .At least meaningful to the extent that Banks don’t get the hit
of ‘Reputational Risk’ and the billions of dollars outflow accounted to penalty.
That in effect frustrates the
crime & terror networks.
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