Are you responsible for a financial crime compliance program? If so, one of the things that keeps you up at night is how to improve the efficiency of your program. In conversations with your staff and colleagues at other organizations, many ideas are discussed – better data, cleaner processes, more technology, and more.
Let’s look at some ways you can work on this ongoing challenge…
Improving Data Quality
Compliance programs require accurate data sets from around your organization. There's a balance between the criticality of having the correct data and the time spent gathering that data. You are never going to have all the data that you want.
To improve data quality, focus on these five areas:
- Work with your partners running the different business segments. They're managing the customers, they're selling the products, and they see the transactions. They own the data.
- Make clear the data elements you need.
- Make clear the quality level you need.
- Concentrate on making these requirements as straightforward as possible.
- Reach an agreement about the completeness and quality your partners will deliver.
Fully Use the Systems You Have in Place
Many of the systems used in existing programs are not being fully utilized. They are still running with their default settings or have not been tuned in a long time. Tune your systems now and on an ongoing basis. Perform a complete coverage assessment to ensure the proper rules are turned on.
Don't be afraid to turn off rules in your current system if they are unproductive. Document why it is not a productive rule, identify a compensating control, and turn it off.
Adding Technology and Advanced Analytics
Technology has played an increasing role in compliance programs for many years. Initially, it helped bring information together. Later it helped identify individual transactions that needed closer review. Now technology and advanced analytics can streamline compliance tasks and improve program efficiency.
Manual administrative tasks cause many inefficiencies. These include gathering data from multiple systems, documenting what data has been collected, documenting that required procedures have been followed, and documenting the analysis performed and the conclusion reached.
By automating these tasks, your staff can focus on analyzing behaviors and determining if something is risky or suspicious. You also increase consistency, improving the overall quality of the program.
Automate the SAR Filing Process
A key output of compliance programs is filing Suspicious Activity Reports (SARs). While many SARs require thoughtful judgment in deciding whether to file, there are opportunities to automate the SAR filing process in some cases. One example is SAR filings for structuring transactions.
Suppose there is apparent structuring for a customer. In that case, it's relatively easy to identify, put that data into an Excel spreadsheet to add to a SAR, add a templated narrative to SAR describing to pattern and stating that this customer appears to be structuring transactions, and populate the form using robotic process automation.
Then it just takes a quality assurance process to review them.
To successfully improve your program’s efficiency, ensure you're weaving innovation into your program sustainably. Use a process or a program mindset and not a project mindset.
Innovate your program based on a risk-based mechanism rather than solely in response to a regulatory enforcement action, an audit, or another external driver. Make program innovation business as usual to maintain the momentum of innovation.
Establish performance monitors for your program. These will give insights into what is happening and allow you to recognize what needs immediate attention.
Focus on the few most important things. AML programs are complex, and they’re hard to run. You need to make the problems smaller when you're trying to innovate. Assess the amount of work it will take to bring the change to life, test it, implement it, and monitor it.