Transaction Monitoring & Analytics
European Headquartered Global Investment Bank
In response to Anti-Money Laundering (AML) related regulatory enforcement actions in multiple jurisdictions, a large international investment bank engaged a Gracechurch Co-Founder, with the mandate to transform and also operate all transaction monitoring and analytics controls, globally.
The transformational activity commenced with the definition of a multi-year Financial Crime strategy for AML monitoring, predicated on;
• New policies for modelling, investigations and Suspicious Activity Report (SAR) reporting;
• Standardisation of models, technology and investigative processes, in all operating locations;
• Increased and improved use of analytics;
• Controlled introduction of robotics and machine learning based alert auto elimination;
• Introduction of systematic model tuning;
• Centralisation of model definition, and the introduction of independent model validation;
• Creation and population of a global data lake;
• Implementation of data quality, completeness and lineage controls;
• SAR intelligence sharing across the enterprise;
• Enhanced governance and reporting.
Under the direction and oversight of the Gracechurch Co-Founder, the associated transformation programme, in its first two years, successfully fulfilled the following elements of the strategic end state;
• Global implementation of model management, investigation standards and SAR reporting policies;
• The definition of product based monitoring standards, predicted on the applicability of over 30 “red flags”, which subsequently formed the basis of model standardisation;
• Upgrade of all but one of the strategic transaction monitoring platforms;
• Initial decommissioning of non strategic transaction monitoring platforms;
• Significant increase in the size of the Analytics teams globally, and realignment under a unified management structure;
• Analytics based implementations for all new complex models and topologies;
• Use of machine learning both to facilitate model tuning and also successfully piloted for alert auto-elimination;
• Establishment of a global data lake, partially populated, together with the implementation of a number of supporting data quality, completeness and lineage controls;
• Enhanced global governance which enabled the sharing of SAR intelligence, resulting in the exiting of a number of global client relationships.
In addition, the Gracechurch Co-Founder represented the bank in all Transaction Monitoring related discussions with Regulators globally, and also with the various in-house compliance monitors appointed by the respective regulatory authorities.