PRACTICAL SOLUTIONS
There are critics of the five whys . One primary criticism of the five whys method is relying on the knowledge or judgment of the performer . The process is not repeatable , meaning two people attempting to find the root cause of a problem may arrive at two different root causes . A second criticism is that the method may result in the simplification of problems . Using the late check example in Table 1 , perhaps the issue is not that the company did not adequately cross-train but that the turnover in the company is so great that it makes cross-training impossible .
Even with the potential drawbacks to the five whys for root-cause analysis , the use in constructing clear , concise and foundational EDD conclusions is hard to ignore . In fact , the five whys are a form of “ mind mapping .” As shown in Graphic 1 , mind mapping is a “ structured way to capture and organize ideas and information . They help users to understand concepts by breaking them down into their component parts …. A mind map is built around a single central topic . All the information on your map is ‘ anchored ’ to the same start point . By placing the main idea at the center , [ it is ] easier for others to understand the core focus of the mind map .” 5
Graphic 1 : Visualization of mind mapping
Supporting idea
Subtopic 1 Subtopic 2 Subtopic 3
Central topic
Source : MindMaps 6
Conclusion
The main focus of an EDD analysis is the conclusion ( e . g ., the activity is reasonable , or the customer is risky , etc .). The investigator can build on that central focus by utilizing the five whys method , building the supporting ideas off each “ why ” they have answered .
By utilizing the five whys method in the EDD analysis process , an investigator increases the likelihood that his or her analysis will appropriately support the risk conclusion drawn . The five whys can assist an investigator in transforming a summary of facts into a conclusion supported by data and evidence .
Amy Wotapka , CAMS , BSA and OFAC officer , First American Bank , USA
1
“ Information on Complying with the Customer Due Diligence ( CDD ) Final Rule ,” Financial Crimes Enforcement Network , https :// www . fincen . gov / resources / statutes-and-regulations / cdd-final-rule
2
“ Assessing Compliance With BSA Regulatory Requirements : Customer Due Diligence ,” FFIEC Bank Secrecy Act / Anti-Money Laundering InfoBase , https :// bsaaml . ffiec . gov / manual / AssessingComplianceWithBSARegulatoryRequirements / 02 _ ep
3
Ibid .
4
“ Assessing Compliance With BSA Regulatory Requirements : Suspicious Activity Reporting — Overview ,” FFIEC Bank Secrecy Act / Anti-Money Laundering InfoBase , https :// bsaaml . ffiec . gov / manual / AssessingComplianceWithBSARegulatoryRequirements / 04
5
“ What is Mind Mapping ? What Are Its Uses ?” MindMaps , https :// www . mindmaps . com / what-is-mind-mapping
6
Ibid .
56 acamstoday . org