Although the identification of suspicious activity is core to an AML solution, an equally important component is the effectiveness of how to manage the investigative processes that follow such alerts. Inconsistent investigative processes, both in terms of approach or in terms of quality, can open up a loophole in the process that can make the whole AML process ineffective. Hence it is important for an MLRO or Head of Compliance to ensure that certain processes, for every case, are adhered to and followed with the same level of thoroughness. With ComplyRadar we try to address this with a number of features.
A key aspect for an effective case management process is to ensure consistency. Each case is different and can fall under a defined set of case categories. The MLRO or Head of Compliance can transpose policies into a set of investigative steps that need to be followed for each case category, ranging from checking of personal details, validation against published lists, analysis of historic activity, etc. The steps define the checks that need to be performed for a particular case type, in which order, and depending on different outcomes how each step conditionally routes to the next. Such an approach guarantees that investigative processes adhere to internal policies and limits errors resulting from inconsistencies or personal human bias.
Another important aspect of an effective Case Management solution is to facilitate decisions for AML officers by bringing all the case facts and information together. As part of an investigation, the AML officer goes through a myriad of data collection and consolidation steps to formulate opinions and be able to make sound decisions. This can range from personal client data, historic transaction activity, external public lists, third party data providers, adverse media checks, etc. The ability to bring together all this information on one screen, avoiding the need for AML officers to navigate through numerous internal and external systems, facilitates a lot the process and helps to present a better holistic picture of the case in question, making the life of the AML officer more efficient and effective.
It is very difficult to strive for an effective and efficient process without being able to measure it. Hence, it is crucial that MLROs and Compliance Officers can ,at a glance, get a picture of the status of the open cases, any particular delays, closure timings, and workload distribution across the team. From a regulatory perspective, it is equally important to be able to receive notifications on certain time bound checks, for example to ensure that a specific check is performed within 24hrs from the moment a case is created.
The case management process also demands a certain level of accountability on the people who are executing the specific investigative tasks. Hence a solution should be able to track the who and when information for each task, all outcomes and approval processes.
Finally, any process should have a mechanism of improvement. Hence it is important for MLROs and Compliance Officers to have the ability to monitor all case activities, evaluate the quality and detail of investigations performed, and be able to attach comments, awards and suggestions for improvement on each particular activity logged into the system.