AML Risk Assessments & Suspicious

Activity Transaction Monitoring

(July 28, 2009)

Deloitte Financial Advisory Services LLP

Michael Shepard
[email protected]
215.299.5260

Copyright © 2009 Deloitte Development LLC. All rights reserved.

AML Risk Assessments - Introduction

• Fundamental component of a risk-based AML compliance program.

• Documents source and quantity of AML risk arising in each Line of Business (LOB).
• Captures details on scope and effectiveness of risk mitigants and control processes used
to manage AML risk.
• Provides Board, Senior Management, LOB, and Compliance Officers with an analytical
assessment of:
‒ inherent AML risk levels arising from customers, transactions and geographies;
‒ risk mitigants and control processes in place to manage this risk, as well as their
effectiveness.
• Beneficial in meeting the needs/expectations of regulators and Internal Audit.

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Risk Assessment Program – Procedures, Templates and
Bottom-Up Process

Risk
Assessment
Procedures
Executive
Summary
Template
Risk Scoring
Template An overview of
the results,
together with key
Assignment of Risk Ratings drivers of the risk
using a standard framework and controls
and terminology for AML
risk

Risk
Assessment An analysis of the sources of AML
Template risk, together with an assessment
of the controls and risk mitigants
in place
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Risk Assessment Program

Inherent AML Risk Factors

Risk Assessment documents each LOB‟s exposure to inherent AML risk factors arising from
three primary areas:

1) Products and services known to have been, or which can potentially be, abused by
money launderers and terrorists;

2) Customers and entities who move large amounts of cash or other funds to disguise „dirty
money‟; and

3) Countries and territories with weak AML controls, with a documented history of corruption
problems, or associated with the production and distribution of narcotics or associated with
terrorism.

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AML Risk Assessment Program

Typical Criteria for Assigning Risk Ratings for Inherent Risks

• Low - Indicates truly minimal activity related to high-AML risk customers or products and
services.

• Medium - Risk is characterized by larger numbers of high-risk customers and volumes

of transactions in high-risk products.

• High - Is appropriate when high-risk customers or products and services are actively
pursued as a business strategy and as a result comprise a material portion of the
customer base, transactions and financial performance.

Note: Many institutions use High and Neutral as an alternative

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AML Risk Assessment Program

Risk Mitigants and Controls

• Risk may be managed, mitigated or, perhaps in some instances, eliminated. “Mitigation
Factors” are those controls that, if properly implemented and maintained on an on-going
basis, could lessen or mitigate some or all of the inherent risk.

• Controls can be preventive (such as checklists, training, written procedures) or detective

(such as monitoring/quality assurance, LOB compliance team testing). Preventive
controls are generally considered to be stronger than detective controls in managing risk.
With appropriate controls in place, even a high inherent risk may be reasonably
managed.

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AML Risk Assessment Program

Assigning Risk Ratings for Risk Mitigants and Controls - Example

• Strong - indicates that the control is in place, well established, extremely effective in
preventing the occurrence of risk events, and performed with an appropriate frequency
that is relevant to the process. A strong control is also performed effectively by the
control group and is periodically tested to ensure it is still in place. For a strong
assessment, there must have been no significant risk events that occurred as a result of
a breakdown of the control.

• Adequate/Medium - rating characterizes a control that is in place, established and

generally effective in preventing the occurrence of risk events. It is performed periodically
and on an acceptable frequency. For a satisfactory rating, such controls must remain in
place and be effectively performed. There must have been no significant risk events that
occurred as a result of a breakdown of the control.

• Weak - describes a control that is not in place although it needs to be, is not particularly
effective in prevent risk events, may not be performed with any particular frequency or on
any scheduled timetable (if one can be ascertained) or there were significant risk events
that occurred and may have been prevented if the control was in place or a stronger
control.

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 PHASE 1: Assessment of the Inherent AML Risk

Example of inherent AML risk assessed across 5 main risk areas. Multiple risk factors are evaluated
within each main risk area to determine the overall inherent AML risk for each country/business.
Legend: For each country / risk 5 Main Risk Areas Examples of Risk Factors Risk Model Snapshot
area / risk factor the inherent
AML risk can be rated on a scale • Maturity/stability
of: 1 Customer Base
• Domicile/residency
• PEP status
Inherent Risk • E-banking
• Indirect customers

Portfolio of product offerings:

2 Product / Account
• Sales finance
• Mortgage
Type Inherent Risk • Life insurance
• Anonymous savings accts

Portfolio of transaction types:

3 Transactional
• Domestic transfers
Inherent AML Risk • Cash deposits
Inherent Risk • International checks
• International transfers

Summary Dashboard
• M&A activity
4 Business Strategy
• Business strategy changes
• Expected growth
Inherent Risk • Product portfolio expansion
• Staff turnover

Country risk rating model:

Summary Dashboard provides an 5 • Positive factors (FATF, EU,
overview of the overall risk for Geography
BIS)
each country by 5 main risk areas Inherent Risk • Negative factors (OFAC, NCCT,
311, offshore, etc.)

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PHASE 2: Assessment of the Residual AML Risk

Step 1: Mitigating controls in form of AML policies, procedures and processes are assessed for
each country/business
Step 2: Residual AML risk is derived by „subtracting‟ mitigating controls from the inherent AML risk
12 Control Areas Examples of Questions Structured Answers

1 General P&P • Is the AML officer certified by

the local authority or a
recognized international
2 Governance organization (e.g., ACAMS)?
POLICIES &
PROCESS PROCEDURE
S
3 Training • Are all new employees required
to attend and pass the initial Y Y
AML training within the first N N
AML Controls
4 Risk Assessment months after being hired?
N/A N/A
Comment Comment
5 Customer Risk Rating • For all individual customers, do
you at minimum obtain the
Summary Dashboard name, DOB, residential address
OVERALL RATING OF CONTROLS 6 CIP / KYC / EDD and identification number?
# Question
PROCESS POLICIES & PROCEDURES

I. General Policies & Procedures STRONG MEDIUM

II.
III.
Governance
Training
MEDIUM
WEAK
STRONG
WEAK 7 PEPs • Do you obtain sign off from
MEDIUM MEDIUM
IV.
V.
Risk Assessment
Customer Risk Rating WEAK WEAK compliance/AML leader and/or
VI. CIP / KYC / EDD MEDIUM STRONG
VII. PEPs MEDIUM MEDIUM senior management for all PEP
VIII. Screening WEAK WEAK
IX.
X.
Surveillance
Reporting
WEAK
STRONG
MEDIUM
STRONG
8 Screening customers?
ASSESSMENT OF CONTROLS
XI. Recordkeeping STRONG STRONG
XII. Auditing / Testing MEDIUM STRONG
OVERALL AML CONTROLS MEDIUM STRONG
Max Count of
9 Surveillance • Do you utilize an automated “N” for each LEVEL
screening filter to match Control Area
Summary Dashboard
provides a summary of the customer names against the 0 STRONG
overall assessment of 10 Reporting Watch list names?
2 MEDIUM
mitigating controls
3+ WEAK
11 Recordkeeping • Do you perform regular testing
of adherence to the AML
program, policies and
12 Auditing / Testing procedures?

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Suspicious Activity Transaction Monitoring
A bank‟s AML program typically consists of multiple core competencies
working together to mitigate risk

AML Compliance
Program Assessment

Technology
Solutions Risk Assessments

Bank’s must
mitigate money
Independent laundering, Develop AML Policies
Testing and Procedures
regulatory and
reputational risks
KYC
AML Training &
CIP

Organization and Transaction Monitoring

Governance Implementation &
Structures Optimization

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Let’s Explore…. 10
Suspicious Activity Transaction Monitoring

Many banks employ a sophisticated approach to customer account opening,

monitoring, and analysis using a combination of technologies.

• Customers are on-boarded and their information is typically entered into a bank‟s
KYC/CIP database. The data is matched against public and private information to
search for risk factors including, but not limited to, PEP status.

• After the new customer completes the KYC/CIP process, accounts are opened and the
risk scores are populated within the customer database.

• All account activity is periodically monitored through the bank‟s Transaction Monitoring
application where risk factors are analyzed in connection with transactional patterns in
search of anomalous activity at both customer and account levels.

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Suspicious Activity Transaction Monitoring

• Comprehensive enterprise-wide account monitoring systems enable the bank to detect

unusual & potentially suspicious activity that may indicate the need for additional internal
money laundering investigations.

• Monitors account activity for unusual transaction patterns or events that exceed
statistical thresholds within pre-defined scenarios. The systems typically utilize temporal
analysis to evaluate transactions over multiple dimensions of time.

• Alerts generated are typically clustered with other intelligence data and reviewed by a
bank‟s Financial Intelligence Unit (“FIU”). The FIU‟s mission is to bring a focused and
proactive approach to the operational aspects of financial crimes deterrence, detection,
and reporting. The result can be an enterprise view of risk from across the organization.

• Many banks use some sort of manual transaction monitoring, particularly for very high
risk areas

• Determine if SAR filing is necessary

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Sample Retail Transaction Monitoring Scenarios

• Structured Cash
‒ Frequent cash deposits under the reporting threshold (e.g., patterns between $8 to
$10k) or instances of periodic round dollar transactions

• High Velocity Wires

‒ Instances of frequent wire activity within an account that exceeds a behavioral
threshold

• High Risk ATM

‒ Instances of unusual ATM withdrawal activity in high risk locations or geographies

• Dormant Accounts
‒ Instances of sudden spikes in an account‟s activity which was previously dormant

• Large Incoming/Outgoing Wire

‒ Instances where an account receives or sends a large wire that is outside the
predefined threshold for that customer segment

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Sample Investment Banking Transaction Monitoring
Scenarios

• Significant changes in trading patterns

‒ Instances of transactions within an account (commodities, securities or foreign
exchange account) that are unusual in total dollar volume, trade size, frequency, or type
of product, given the customer‟s typical trading history

• Stated business of customer not commensurate with type or level of activity

‒ Instances of transactions within an account (commodities, securities or foreign
exchange account) that are unusual in size, frequency, or product, given the
information known about the customer‟s business

• Transactions in an amount beyond the known financial resources of the customer

‒ Instances of transactions, or inflows of funds or assets, in an amount that appears
unusually large given the known financial resources (such as income, revenue or total
assets) of the customer

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Sample Investment Banking Transaction Monitoring
Scenarios (Con‟t)

• Transactions at an off-market rate or price

‒ Instances of transactions within an account (commodities, securities or foreign
exchange account) that are at a rate or price substantially unrelated to the market rate
or price for the product purchased or sold

• Series of transactions (buys and sells) that do not result in change of ownership
‒ Instances of a series of buys and sells of a product within an account on the same day
(commodities, securities or foreign exchange account) that do not result in any change
of ownership of the product, and there does not appear to be any reason for the
transactions

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