Spanish ACAMS Today (Diciembre ’10- Febrero ’11) Vol. 10 No. 1 | Page 3

SPECIAL ADVERTISING FEATURE I n today’s economic climate, financial institutions must address financial crime and compliance in a coordinated fashion. Those that don’t can suffer losses, regulatory censure and fines, and, perhaps equally as important, increased reputational risk. In an age where customer trust and loyalty are at a premium, having already been jeopardized by the recent sub-prime mortgage crisis and global credit crunch (to which, incidentally, fraud was a major cause and component), banks cannot afford to gamble with such high stakes. Yet, the business case driving many consolidation initiatives is, in some way or another, artificially constrained, either by sociopolitical factors or by the limitations of the underlying technology used by the systems that support the banks response to these threats. The reality is many banks are not combining their fraud and anti-money laundering (AML) processes. They continue to maintain separate efforts. Consider the following scenario: Lisa Stack and Mary Hunter work at the same bank and rarely have time to chat. One Monday morning, Lisa, a compliance officer, grabs her coffee and digs into the latest pile of reports on her desk. A customer, Fred Kiter, had a busy weekend. His activity broke rules for Lisa’s excessive cash report. She begins to investigate and notices that Fred made several large ATM deposits. She needs to determine if they are check or cash. She makes a note to dig a little deeper and then moves on to the next case. Meanwhile down the hall, Mary settles in for another day of fraud investigations. As she reviews the check kiting report, Fred Kiter jumps to the front of the pile. His multiple ATM deposits, combined with several check withdrawals, seem suspicious and she delves into an investigation. This scenario is not uncommon in the real world. Two talented and busy investigators working on the exact same case because their processes do not allow for an easy synchronization of compliance and fraud investigations. Banks should consider consolidating their AML and other compliance efforts with their anti-fraud measures, rather than relying on separate alerts and reports. Increased efficiencies, reduced costs and improved enterprise risk management are all recognized by industry analysts, government regulatory and enforcement agencies as the end result of a well executed consolidation strategy. On a daily basis, using FRAML technology to achieve their consolidation goals, banks can ensure that their limited resources are used to investigate suspicious activity that is truly suspicious (true positives), while reducing investigation of activity later determined to be legitimate (false positives). Institutions interested in a consolidated approach need to be prepared for two primary obstacles: Focusing resources to investigate truly suspicious activity reduces the potential costs associated with non-compliance and fraud losses, and helps ensure that the bank’s resources are used to greatest effect. • Overcoming the legacy of the different approaches used to achieve separate AML and anti-fraud goals, • Removing the constraints imposed by the adoption of solutions that rely on first-generation (rules-based) technology. These obstacles present a formidable challenge to banks that wish to (a) maximize the return on their investment in the people, processes and technology associated with their AML and anti-fraud efforts, and to (b) leverage the synergies between these programs to gain the upper hand on financial crime and compliance risks and costs across the institution. Overcoming these challenges will require banks to move away from maintaining separate autonomous programs and unite their fraud and AML strategies at the organizational level. Fortunately, banks can now look to consolidated solutions built on second-generation (behavior-based) technology to address these challenges. Second-generation technology allows for far more than just the automation of core banking system-type reports delivered by first-generation technology. It helps banks move beyond a decentralized, siloed approach to AML and fraud, and consolidate efforts by leveraging investments across fraud, AML and other related compliance functions. Second-generation, fraud and AML (FRAML) technology can consolidate large volumes of information about people, accounts and transactions from a variety of disparate data sources – making it easier to spot bad guys by increasing the transparency between customer behavior and the risk exposure to financial crime schemes that fall outside of the gray areas that plague first-generation rules-based systems. In the scenario described earlier, a consolidated FRAML approach would work like this: Mary and Lisa have changed their process. They’ve combined all alerts into a single system, which Mary reviews. She’ll work fraud alerts on her own, but when something looks like it might be money laundering she calls on Lisa for help. This process allows Lisa to focus m