An effective financial crimes compliance program is all about the data. Every control process has a strong data requirement:
• Transaction monitoring for suspicious activity;
• List screening for sanctions and similar controls;
• CIP and risk-based CDD/EDD;
• AML and fraud investigations; and
• Risk Assessment
It all comes down to the data.
An institution’s data sets are often a reflection of the history of the institution. As an institution grows over time, as it upgrades or replaces older systems for newer systems, as it buys branches or portfolios of accounts, as it acquires or merges with other institutions, the quality of its data sets can be subject to degradation. Data from older systems or that originated with another institution can include some interesting abbreviations or even truncations to fit customer names and addresses into fixed field lengths. Data fields can shift in transmission from one system to another, with state codes as the city and country code as the state. There are many ways an institution’s core data can end up less than ideal for our contemporary analytical needs. And as the adage says, garbage in…could result in a fine from OFAC.
I can work with you to analyze the quality of your data – its completeness and accuracy – in the context of the data requirements of your monitoring systems and other control processes. I will identify what types of data errors are common and, where possible, the root cause of the issue. I will provide you recommendations for a prioritized approach to data remediation, and can, if needed, project manage the remediation as well.