The Napier AML Maturity Model - EM360

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The Napier AML Maturity Model - EM360
The Napier
AML Maturity
Model

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The Napier AML Maturity Model - EM360
Contents
                                                                                                  Foreword                                        3
                                                                                                  What is the Napier AML Maturity Model (NAMM)?   5
                                                                                                  Analysis through the six lenses                 6
                                                                                                  Defining the stages of the maturity model        8
                                                                                                  Lens 1: Strategy                                9
                                                                                                  Lens 2: People and culture                      11
                                                                                                  Lens 3: Process                                 13
                                                                                                  Lens 4: Data                                    15
                                                                                                  Lens 5: Analytics                               17
                                                                                                  Lens 6: Infrastructure                          19
                                                                                                  Conclusion                                      21
                                                                                                  Getting to the next level                       22
                                                                                                  Who is Napier?                                  23

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The Napier AML Maturity Model - EM360
Foreword

Today technology is rightfully recognised                                           The entire approach to how technology         The amount of money laundered                   Criminal behaviours are evolving
                                                                                                                             01                                              04
as a powerful means to solve some of the                                            can enable efficiency and drive               each year continues to increase,                and remain a step ahead
biggest challenges in fighting financial                                            results specifically for AML needs            with reports of $3tn laundered
crime.                                                                              deep understanding.                           globally in 2019

However, implementing technology into an                                            The reasons for doing so are numerous:        Regulatory bodies are applying                  Legacy technology is inefficient,
                                                                                                                             02                                              05
organisation comes with its unique set of                                                                                         increasing pressure on                          and in many cases is no longer fit
challenges.                                                                                                                       organisations to take AML seriously             for purpose
                                                                                                                                  by the way of issuing larger fines
Technology for technology’s sake is
no answer.                                                                                                                        Existing siloed approaches to AML               Greater efficiency brings reduced
                                                                                                                             03                                              06
                                                                                                                                  are not effective in fighting financial         costs and reduces regulatory risk
                                                                                                                                  crime or reducing the risk of being
                                                                                                                                  fined by the regulator

                                                                                                                                                                            Continued overleaf...

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The Napier AML Maturity Model - EM360
FOREWORD

That’s why we designed the Napier                                                 We have helped our clients draw a road
                                                                                                                                 How does the Napier AML Maturity Model (NAMM)
AML Maturity Model to help regulated                                              map and implement technology to move           benefit organisations?
organisations who are looking to upgrade                                          them from varying stages of maturity
or replace their existing AML technology                                          in AML to a proactive position which           The NAMM has been designed to give          damage, the stakes have never been
to identify current state and what best                                           embraces state-of the-art technology, AI       organisations a means to perform an         higher to get AML right.
practice looks like.                                                              and real-time search.                          assessment of where their organisation
                                                                                                                                 stands in terms of AML strategy             There are two basic questions an
We have been in the unique position                                               In putting together this document, it is our   (specifically with regards to use of        organisation should ask: do we know
of assisting our clients – from Tier 1                                            intention to share with you what we have       technology), to monitor progress in         what a successful AML programme
banks to fintech start-ups - to identify                                          learned, and hope that you may find the        improving maturity, and to implement        looks like, and do we know the stages
and overcome these challenges.                                                    following insights valuable.                   benchmarks in order to identify             of how to get there?
We understand many of the hurdles                                                                                                best practices.
associated with the successful                                                                                                                                               The NAMM focuses on identifying the
implementation of technology to combat                                                                                           In a world where losing the fight against   current level of maturity, and how to
financial crime.                                                                                                                 financial crime has huge consequences       move your organisation to reach a
                                                                                                    Julian Dixon                 for organisations, both in terms of         leading state of maturity.
                                                                                                    CEO                          monetary loss as well as in reputational

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The Napier AML Maturity Model - EM360
INTRODUCTION

What is the Napier AML
Maturity Model (NAMM)?
The NAMM has been                                                            The maturity model follows a
                                                                             4-step process:
designed to help
regulated organisations                                                         01                             02                              03                              04
understand the status of,
                                                                             Assess the current situation     Define a quantitative           Identify the gaps               Provide tangible steps
and continuously improve                                                     Assess and measure the           target state                    Identify the gaps between the   Provide tangible steps to move
their AML and compliance                                                     maturity of existing AML         Define a quantitative target    current state and the desired   organisations from siloed AML
                                                                             functions and practices          state that can be achieved by   state                           processes through to an end-
capabilities to move the
                                                                             against best industry practice   continuously improving the                                      to-end client compliance view
organisation through to an                                                   as guidelines                    current functions, processes
optimal state for combating                                                                                   and systems

financial crime.

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The Napier AML Maturity Model - EM360
OVERVIEW

Analysis through the
six lenses
In the figure overleaf, the                                                   The model sets out the following six high
                                                                              level lenses, each broken down into a
model uses lenses and                                                         further five sub-categories:
dimensions to assess
and gain a deeper
understanding of an
organisation’s current
                                                                              1. Vision and            2. People and            3. Process               4. Data                 5. Analytics             6. Infrastructure
situation, and then                                                           strategy                 culture                  1. Policies              1. Data Quality         1. Data Analysis         1. User interface
understand how to move                                                        1. Vision                1. Culture and Leaders   2. Procedures and       2. Data Modelling       2. Sandbox and Impact   2. Accessibility
                                                                                                                                    workflow                                         Analysis                 (Search)
forward to an optimal                                                         2. Strategic Planning    2. Functions and                                 3. Data Accessibility
                                                                              3. Governance                Organisation         3. Scenarios and Rules   4. External Data       3. Machine Learning      3. Auditability
position.                                                                     4. Performance          3. Team                  4. Alert Management          (Structured)        4. Dashboarding          4. Scalability
                                                                                  Management           4. Roles                 5. Case Management       5. External Data       5. Reporting             5. Integration
                                                                              5. Performance                                                                (Unstructured)
                                                                                                       5. Knowledge Sharing
                                                                                  Tracking

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The Napier AML Maturity Model - EM360
OVERVIEW

                                                                                                                                                                    LENSES

                                                                                                                   VISION &      PEOPLE &
                                                                                                                                                       PROCESS                  DATA                  ANALYTICS   INFRASTRUCTURE
                                                                                                                   STRATEGY      CULTURE

                                                                                                                                  CULTURE &
                                                                                                                     VISION                            POLICIES              DATA QUALITY         DATA ANALYSIS    USER INTERFACE
                                                                                                                                 LEADERSHIP

                                                                                                     DIMENSIONS
                                                                                                                                                                                                      SANDBOX &
                                                                                                                   STRATEGIC    FUNCTIONS &          PROCEDURES &               DATA                               ACCESSIBILITY
                                                                                                                                                                                                       IMPACTS
                                                                                                                   PLANNING     ORGANISATION          WORKFLOW                MODELING                               (SEARCH)
                                                                                                                                                                                                       ANALYSIS

                                                                                                                                                      SCENARIOS &              DATA                   MACHINE
                                                                                                                  GOVERNANCE       TEAM                                                                             AUDITABILITY
                                                                                                                                                         RULES             ACCESSIBILITY              LEARNING

                                                                                                                  PERFORMANCE                           ALERT              EXTERNAL DATA
                                                                                                                                   ROLES                                                         DASHBOARDING       SCALABILITY
                                                                                                                  MANAGEMENT                         MANAGEMENT            (STRUCTURED)

                                                                                                                  PERFORMANCE   KNOWLEDGE               CASE               EXTERNAL DATA
                                                                                                                                                                                                      REPORTING     INTEGRATION
                                                                                                                    TRACKING     SHARING             MANAGEMENT           (UNSTRUCTURED)

                                                                                                                                     Figure 1. High level overview of the Napier AML Maturity Model

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The Napier AML Maturity Model - EM360
OVERVIEW

Defining the stages of                                                                                                                                                                                           5. LEADING
the maturity model                                                                                                                                                                                           • Proactive AML
                                                                                                                                                                                                                function, centered
                                                                                                                                                                                                                on clients
                                                                                                                                                                                                             • KPIs and KRIs
The objective is to establish                                                                                                                                                                                  driving business
                                                                                                                                                                                          4. MATURE
where an organisation’s                                                                                                                                                                                        outcomes
                                                                                                                                                                                     • Machine learning     • Highly specialised
vision, capabilities,                                                                                                                                        3. MANAGED
                                                                                                                                                                                        adopted to drive        team focused on
processes and technology                                                                                                                                 • Strong process-             value (decrease         investigations
                                                                                                                                2. IMPROVING                based foundation            risk and cost)       • S
                                                                                                                                                                                                                tate of the art
currently fit into the model.                                                                                                                            • Consolidated             • Client-centric         systems
                                                                                                                              • Reactive                                               view of compliance
                                                                                                            1. INITIAL                                      rules based on                                   • A
                                                                                                                                                                                                                I and machine
                                                                                                                              • Key systems in            risk policies             • Optimised rules        learning used to
This figure summarises the                                                                             • O
                                                                                                          ver reliance on     place (TM, TS, etc.)        continuously                 and scenarios          drive work and
                                                                                                         excel spreadsheets   • Minimal workflow           improved                                            minimise risk
factors that constitute the                                                                            • Rudimental rules
                                                                                                                                                                                     • End-to-end
                                                                                                                              • Inconsistent Data       • K
                                                                                                                                                            PIs in place               workflow and         • R
                                                                                                                                                                                                                eal-time search &
different levels of maturity in                                                                        • Email workflows         model                     and monitored                automation             investigations

organisations.                                                                                            Siloed View                                                                                          Client Centric
                                                                                                                                        Figure 2. Moving from a siloed view to a client centric view

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The Napier AML Maturity Model - EM360
THE SIX LENSES

Lens 1: Strategy
The most important element of                                                                          In the context of the In the context of the
                                                                                                       Napier AML Maturity Model, the optimal
building the strategy is taking a                                                                      position for an organisation would be the
proactive stance, starting with the                                                                    Leading Stage where a Client Centric AML
                                                                                                       approach is adopted, and state-of the-
vision itself, and to ask the question:
                                                                                                       art technology, AI and real-time search
                                                                                                       functions are default.
“Where do we want to get to as
an organisation?”

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The Napier AML Maturity Model - EM360
THE SIX LENSES

Lens 1: Strategy
                       INITIAL                                          IMPROVING                           MANAGED                         MATURE                           LEADING                             BEST PRACTICE TARGET

Vision                 The AML functionis seen as                       Fulfil regulations and advise       The AML functionis seen as      Value-added collaboration        Proactive - business partner        Working together with the regulator to drive the change
                       reactive and mainly a ‘back-                     the business when specific          core risk-mitigating function   with the business to mitigate    predicting new threats              The organisation becomes a proactive business partner predicting
                       office’ function with limited                    risks are identified. Still         supporting the business.        risk and to improve customer     before they emerge and drive        new threats before they emerge, driving revenue through customer
                       business impact.                                 mainly seen as a ‘back-office’                                      insights.                        revenue through customer            insights.
                                                                        function.                                                                                            insights.

Strategic              Minimal planning defined only                    High level roadmap                  Plans to improve AML            Strategic plans are defined      3-year plan, with quarterly         Defining the roadmap to improve the AML function and budget for
                       for audit points and high-risk                   defined to implement and            functions in place, budgeting   to continuously improve the      refresh, agile methodology          innovation
Planning               areas. Initiatives defined and                   deploy regulatory change            and costing reviewed            AML function; investments        applied. Budget allocated for       The organisation defines a 3-year plan for transformation which is
                       managed tactically.                              programmes. Bespoke local           periodically with global        & budgets allocated for          innovations and research.           reviewed quarterly. Agile methodology is adopted for implementation
                                                                        initiatives in place.               change function in place.       improvements.                                                        and there is a budget allocated for innovations and research.

Governance             High level roles and                             Governance for key processes        Central governance              Central governance driving       Centre of excellence for            Becoming a centre of excellence driving capital investments
                       responsibilities defined                         defined (e.g. first/second          established and is              the AML function globally.       policies and system design.         The organisation becomes a centre of excellence for policies and
                       but lack of consolidated                         line of defense), Roles and         responsible for transforming    Periodic interaction with        Regulatory board to discuss         system design. A Regulatory board is formed to discuss policies with
                       governance across areas and                      responsibilities documented.        the AML function.               regulators and business          with regulators and innovate.       regulators and drive innovation.
                       workstreams.                                                                                                         driving the agenda.

Performance            No KPIs and KRIs defined,                        KPIs and KRIs are defined           KPIs and KRIs are in place      KPIs and KRIs are in place and   KPIs and KRIs proactively           Becoming an organisation driven by KPIs and KRIs
                       Resources focus on closing                       at a high level. However no         and are used to drive team      periodically reviewed. Minimal   managed. Metrics granularity        KPIs and KRIs proactively managed. Granularity in metrics allows
Management             alerts and cases. Inconsistent                   performance management              performance forward and         root cause analysis on poor      allows for root cause analysis      organisations to analyse the root cause of issues and determine how
                       performance across teams.                        process are in place.               reduce risk.                    performing metrics in place.     of issues and resolution.           to resolve these.

Performance            Performance is not tracked                       Performance metrics                 Performance metrics are         Performance metrics are          Performance metrics are             Tracking performance for continuous improvement
                       across areas and teams.                          are tracked manually                automatically tracked and       automatically tracked with       automatically tracked with          Performance metrics automatically tracked with detailed dashboards
Tracking                                                                across teams with manual            collated across teams for       detailed dashboards.             detailed dashboards and             and analysts can drill down to specific areas. Organisations will need
                                                                        performance summaries.              management review.                                               ability to drill down to specific   to implement technology that has capability to produce the desired
                                                                                                                                                                             areas.                              metrics in order to achieve automation.

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THE SIX LENSES

Lens 2: People and culture
Any program of change needs to                                                                        To move an organisation to a place of AML maturity, there
                                                                                                      are several further factors that need to be considered,
consider, as its top priority, how                                                                    especially in view of AI being very much part of a
transformation will affect people and                                                                 technological solution for AML maturity.

culture in an organisation.
                                                                                                      Taking this into account, the most important goal
                                                                                                      should be to minimise operational resources while
                                                                                                      simultaneously maximising the talent in specialised teams
                                                                                                      such as AI and data science teams.

                                                                                                      One of the challenges worth noting about introducing
                                                                                                      an AI capability is that talented data scientists with
                                                                                                      experience in compliance and financial services can be
                                                                                                      difficult to source. And therefore, it is prudent to plan for
                                                                                                      this in terms of time and resources.

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THE SIX LENSES

Lens 2: People and culture
                       INITIAL                                          IMPROVING                           MANAGED                          MATURE                            LEADING                          BEST PRACTICE TARGET

Culture &              Command and control                              Risk management culture             Objectives are defined           Talent is managed across          Empowering teams and             Talent managed across functions, leadership
                       approach, micromanagement                        in place across teams and           and shared across teams.         functions and teams, high         individuals to make the          development programme
Leadership             of tasks. Business objectives                    functions with clearly defined      Initiative is rewarded and       degree of collaboration across    right choices. Leadership        Empowering teams and individuals to make the right choices.
                       and knowledge is minimally                       objectives and strategy.            team members empowered.          teams.                            development programmes in        Leadership development programme.
                       shared.                                                                                                                                                 place.

Functions &            Each function within AML                         Functions are localised with        Increased specialisation leads   High degree of functional         Functions share objectives       Functions are centered around a holistic client view to support
                       is siloed and processes                          minimal standardisation of          to improved collaboration        specialisations (operational,     and visions and clearly          risk management
Organisation           are often repeated across                        tasks and repetitions within        between functions, on-shore      investigative, etc.) supporting   aligned with revenue             Functions share objectives and visions; and clearly aligned with
                       teams. Nonstandard work per                      functions.                          vs off-shore in place to limit   business functions.               generating functions to          revenue generating functions to support risk management.
                       location.                                                                            costs.                                                             support risk management.

Team                   Local teams performing                           Minimal centralisation of           Several centralised              Limited operational               No operational processes due     Minimal operational processes, highly specialised teams
                       inconsistent processes. Lack                     teams for shared activities,        processing units (e.g. to        processes due to high level       to AI & automation. Central      No operational processes due to AI & automation. Central regulatory
                       of global guidelines.                            mainly localised teams.             manage alerts), localised        of automation and AI; teams       regulatory strategy team,        strategy team, automated investigations.
                                                                                                            compliance team to manage        focus on case mgmt. and           automated investigations.
                                                                                                            cases & investigations.          regulatory change.

Roles                  Focus mainly on operational                      Minimal degree of                   Increased role specialisation:   Decrease in operational roles,    Focus on high value roles        High value adding roles, data scientists, investigators
                       roles (e.g. alerts review). Lack                 specialisation, different types     data engineers and data          high degree of specialisation     including data science (to       Focus on high value roles including data science (to build new
                       of specialisation. Leverage                      of operational roles focus on       scientist roles are present in   and increased emphasis on         build new models), analytical    models), analytical investigation and data engineer positions.
                       external consultants.                            different parts of the process.     the organization.                investigative and analytical      investigation and data
                                                                                                                                             roles.                            engineer positions.

Knowledge              Limited knowledge sharing                        Knowledge sharing limited           Internal repository of           Clearly defined processes         Knowledge and best practice      Knowledge sharing in KYC, transaction monitoring, AML
                       based on emails.                                 to procedures and policies,         good practice (processes,        to share information and          is shared, and periodic events   Knowledge and best practice are shared, and regular events are
Sharing                                                                 however stored on wword             procedures, patterns) is         knowledge gained on cases,        are hosted to share findings     hosted to share findings and achievements with the industry and
                                                                        documents shared via emails.        defined and knowledge is         documents shared centrally.       and achievements.                peers.
                                                                                                            shared.

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THE SIX LENSES

Lens 3: Process
The Client Centric approach is                                                                        Introducing automation for routine and repetitive
                                                                                                      tasks allows analysts to reallocate their time into more
underpinned by a focus on operational                                                                 important tasks.
excellence and streamlined processes
                                                                                                      The use of dynamic rules which are linked to the
which are driven by automation.
                                                                                                      organisation’s policies help reduce false positives while
                                                                                                      machine learning is used to increase efficiency.

                                                                                                      Integrated case management across the client lifecycle
                                                                                                      including monitoring, screen and review is fully
                                                                                                      automated.

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THE SIX LENSES

Lens 3: Process
                       INITIAL                                          IMPROVING                             MANAGED                                MATURE                               LEADING                              BEST PRACTICE TARGET

Policies               Policies are defined at a high                   Policies are clearly defined with     Policies are defined and               Policies are centrally managed       Policies centrally managed and       Policies are continuously improved and proactively managed
                       level to ensure compliance with                  adequate depth and detail and         centrally managed and stored in        and reviewed regularly, with clear   reviewed regularly. Interactions     Policies are centrally managed and reviewed regularly. Interactions
                       current regulations.                             stored on word document with          consistent formats.                    governance to manage updates         with lawyers and regulators to       with lawyers and regulators to add new policies.
                                                                        inconsistent formats.                                                        and versions.                        add new policies.

Procedures &           Procedures definitions are limited               Limited uses of workflow, mainly      Processes are clearly                  Processes are managed through        90% of the process is automated,     High degree of process automation driven by AI
                       to word documents describing                     implemented on legacy systems.        documented (e.g. BPMN)                 standard workflow applications;      leveraging AI. Investigative         90% of processes are automated leveraging AI. Investigative
Workflow               the steps required to perform a                  Limited ability to track processes.   however the execution is spread        Every process is tracked and         processes managed on a               processes are managed on a standard workflow platform.
                       process. No workflow in place.                                                         across multiple systems.               process mgmt. is in place.           standard workflow platform.

Scenario &             Rules defined on spreadsheets                    Rules are hard-coded within           Rules for monitoring, screening,       Rules are managed within             Dynamic rules-based                  Dynamic rules implemented resulting in minimal false positives
                       and macros that need to be                       system and high degree of IT          etc. are managed within                systems and key parameters can       approach linked with policies.       Dynamic rules, linked to the organisation’s policies, are
Rules                  manually updated on a monthly                    intervention is required to amend     controlled applications and            be amended by specialised users      Machine learning used to             implemented. Machine learning is used to increase the efficiency
                       basis with extracts of data.                     them.                                 properly documented.                   with minimal IT intervention.        increase efficiency and              and effectiveness of scenarios.
                                                                                                                                                                                          effectiveness of scenarios.

Alert                  Reactive alert management                        Alert management process is           Alert management based on              Alert management process highly      Alert management process             Alert management highlighting true unusual behaviours with most
                       process triggered by static rules.               managed on workflow, but high         static risk profiles and thresholds.   effective. Minimal amount of false   focuses on high risk behaviours      relevant datapoints
Management             >99% false positives and high                    degree of false positives hinder      Ability to manually tweak              positives (
THE SIX LENSES

Lens 4: Data
Getting data right is fundamental in                                                                  Data comes in all forms and, in AML, it is becoming
                                                                                                      increasingly important that a system can ingest
ensuring that an organisation has an                                                                  unstructured and structured data, and that it makes that
optimal AML defense, and it is probably                                                               data accessible to users in real-time.

the biggest challenge that most
organisations face when transforming
their systems and processes.

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THE SIX LENSES

Lens 4: Data
                         INITIAL                                          IMPROVING                              MANAGED                             MATURE                                 LEADING                                BEST PRACTICE TARGET

Data quality             Multiple, inconsistent data                      Multiple inconsistent data             Standard data definitions,          Data lake consolidating all critical   Single data repository for             Highest data quality standards with big data used as repository for
                         repositories with poor customer                  repositories holding information       multiple systems holding            data in single repository; however     transactions and customers,            all datapoints
                         and transaction data quality. High               related to customers and               different data, single version      data is difficult to traverse due to   high quality information, ability to   Single data repository for transactions and customers, high quality
                         amount of spreadsheets.                          transactions. No spreadsheets          of the truth, data cleansed and     poor quality.                          access all data in real-time. Big      information, ability to access all data in real-time. Big data fabric.
                                                                          used for sensitive data.               standardised.                                                              data fabric.

Data Modelling           Limited definition of customer                   Standard data models are defined       Standard data models and            Standard data models in place,         Standard data models in place,         Standard data models across functions and single view of the client
                         and transactions inconsistent                    globally, however there is at least    hierarchical structure are in       ability to ingest additional data      ability to ingest additional           Standard data models in place, ability to ingest additional data using
                         across regions, business and                     20% of inconsistencies in local        place. Clear data taxonomy and      using transformation tools             data using intuitive data              intuitive data transformation tools.
                         products.                                        definitions.                           ontology. Data models applied       requiring minimal IT support.          transformation tools.
                                                                                                                 locally.

Data                     Data accessed and shared via                     Data is accessed via specific          Data can be accessed on multiple    Data can be accessed by multiple       Ability to access the data based       Data accessible in real-time by the right part of the organisation
                         excel spreadsheets shared via                    applications; however IT is often      platforms but minimal controls on   roles including data scientist         on roles. Each user can see            Ability to access the data based on roles. Each user can see subset
Accessibility            email with limited security and                  required to provide extract of         contents that are accessed.         that can leverage data to build        subset of data based on roles +        of data based on roles + geography. Access is tracked.
                         controls.                                        data.                                                                      models.                                geography. Access is tracked.

External Data            Limited use of external open-                    Use of bespoke commercial data         Integration with high quality       Integration with disparate data        Use high quality structured data       High quality structured data used to enhance investigations and
                         source data (e.g. OFAC lists)                    solution, with limited data quality.   external risk data (e.g. DJ,        sources to perform screening           for screening, due diligence, and      reduce false positives
(Structured)             to enhance screening and                                                                Refinitiv) used on screening and    and minimise false positives by        investigative intelligence. Use        Use high quality structured data for screening, due diligence, and
                         monitoring processes.                                                                   monitoring processes.               leveraging multiple datasets.          external due diligence services.       investigative intelligence. Use external due diligence services.

External Data            Limited use of external data,                    Limited integration with               Integration with unstructured       Ability to access unstructured         Ability to access articles, news       Unstructured data to enhance screening and monitoring. AI used to
                         mainly via web searches (e.g.                    unstructured data repositories,        data repositories (e.g.             data repositories and process          and media to enhance screening         extract relevant info
(Unstructured)           google) to run investigations.                   with searches performed                MeltWater, Factiva) for search &    information using machine              and monitoring processes.              Ability to access articles, news and media to enhance screening and
                                                                          manually.                              investigation.                      learning on an ad-hoc basis.           Minimise false positives.              monitoring processes. Minimise false positives.

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THE SIX LENSES

Lens 5: Analytics
Just as getting data right is                                                                          In the leading stage, the use of machine learning can
                                                                                                       empower analysts and support analytics. When used
fundamental in configuring an                                                                          correctly, machine learning models, both supervised and
optimal AML solution, having powerful                                                                  unsupervised, can provide insights and context into client
                                                                                                       behaviours that may otherwise not be detected.
analytics is critical for analysts to make
rapid interventions.                                                                                   Having good analytics dashboards puts the power of the
                                                                                                       data at the fingertips of the analysts, giving them the
                                                                                                       ability to slice and dice the data, drill down into the detail
                                                                                                       and define and track KPIs with ease.

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THE SIX LENSES

Lens 5: Analytics
                      INITIAL                                          IMPROVING                            MANAGED                            MATURE                              LEADING                                BEST PRACTICE TARGET

Offline               Limited analysis performed on                    Key relevant data aggregated         Data warehouse in place to         Big Data repository allowing        Ability to run offline analytics       Detailed analytics available to provide client insights
                      excel spreadsheets.                              in access database. Standard         perform offline analysis (month-   to run multiple queries on          on big data, run multiple              Ability to run offline analytics on big data, run multiple aggregation,
Analysis                                                               queries provided. SQL knowledge      end); predefined aggregation.      aggregated data across multiple     aggregation, drill down and            drill down and analyse networks.
                                                                       needed for analysis.                 Lack of granular drill-down.       dimensions. Limited drill down.     analyse networks.

Sandbox               Impact analysis is usually                       Minimal automation on excel/         Standard tools are deployed in     Current applications allow to       Ability to run multiple what-          Ability to run scenarios on dedicated sandbox
                      performed on bespoke tools (e.g.                 Microsoft Access based on            the organisation to run what-      tweak scenarios parameters          if scenarios with a copy of            Ability to run multiple what-if scenarios with a copy of production
& Impact              SQL/Access databases). The                       macro. Process is mostly manual.     if analysis; however, they are     and test on data; however IT        production data without impacts        data without impacts on production system.
Analysis              process is manual.                                                                    mainly MS Access based.            knowledge is required.              on production system.

Machine               No machine learning capabilities.                Minimal statistical analysis         Scripts deployed to focus          Machine learning functionalities    Supervised and unsupervised            Machine learning models used to provide insights on clients and
                                                                       deployed on bespoke scripts/         on specific areas (e.g.            are embedded in systems and         models, NLP, suggested actions         transactions
Learning                                                               tools. Use of MATLAB/R to            false positives detection,         processes to detect anomalies       and AI models that can be              Supervised and unsupervised models, NLP, suggested actions, AI
                                                                       perform offline analysis.            behavioural analysis). Limited     and automate complex analyses.      amended by users embedded in           models that can be amended by users embedded in systems.
                                                                                                            productionisation.                                                     systems.

Dashboarding          No dashboarding capabilities.                    Limited dashboard produced via       Dashboard are generated on the     Different dashboards available      Dashboards available based on          Ability to slice and dice data and provide bespoke analytics
                                                                       excel pivot table and pivot charts   back of the data warehouse/        based on different roles, however   roles, drill down, ability to define   Dashboards available based on roles, ability to drill down and define
                                                                       with data manually uploaded on a     systems.                           limited ability to drill down to    bespoke KPIs per user and track        bespoke KPIs per user; and track across multiple charts.
                                                                       monthly basis.                                                          specific datapoints.                across multiple charts.

Reporting             Data is manually extracted                       Standard reports templates are       Standard reports are available     Standard reports are produced       Standard reports automatically         Unstructured data to enhance screening and monitoring. AI used to
                      from systems and manipulated                     available in excel with limited      in each system with limited        daily with exceptions and trends.   produced; bespoke reports can          extract relevant info
                      with spreadsheets to manually                    manual work required to update       customisation. Additional manual   Detailed monthly analysis           be designed on the platform with       Standard reports are automatically produced, bespoke reports
                      generate the required reports.                   data on a monthly basis.             work required to enrich reports.   automatically generated.            limited effort. Pdf exports.           can be designed on the platform with limited effort. Pdf exports
                                                                                                                                                                                                                          available.

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THE SIX LENSES

Lens 6: Infrastructure
Implementing technology to                                                                            Choosing infrastructure that is highly scalable, that can
                                                                                                      grow with increased volumes of data and transactions,
futureproof your organisation should                                                                  gives your organisation a powerful foundation to
be at the forefront when developing                                                                   build from.

an AML strategy.
                                                                                                      Other considerations such as API integration, data sharing,
                                                                                                      accessibility and auditability are all key to ensuring that
                                                                                                      the technology can support a successful AML function.

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THE SIX LENSES

Lens 6: Infrastructure
                         INITIAL                                          IMPROVING                            MANAGED                               MATURE                                LEADING                               BEST PRACTICE TARGET

User                     Inconsistent user experience                     Inconsistent user experience         Multiple User Interfaces across       User interfaces in the majority of    Consistent UX designed around         Applications support the analyst with state-of-the art user interface
                         on different systems. Not user                   across systems                       multiple systems, similar             the systems are designed based        specific users (compliance, data      Consistent UX designed around specific users (compliance, data
Experience               friendly, difficult to train users                                                    processes are performed               on roles                              scientist, manager) based on          scientist, manager) based on their processes.
                         and hinders process execution                                                         differently (e.g. case mgmt.)                                               their processes

Accessibility            Customer and transactional data                  Limited ability to access subset     Data can be accessed directly by      Real-time search on big data          Real-time search on billions          Ability to run searches in real time across multiple data points
                         can be accessed by emailing                      of data through the use of           using specific systems and slices     dataset; ability to access all data   of data, real-time aggregation,       Real-time search on billions of data, real-time aggregation, ability to
(search)                 query details to IT department                   specific systems. IT department      of data can be downloaded on          from a single repository. Queries     ability to slice and dice data on     slice and dice data on platform, pivot table.
                         that will extract offline                        involvement is often required        xlsx for analysis                     are easy to define                    platform, pivot table

Auditability             Limited audit logs available in                  All key processes are performed      Technical audit logs are available    Audit logs are mainly technical       Real-time audit for all activities    All decisions are auditable and the output of machine learning
                         systems or majority of processes                 via applications, however not all    with different level of details in    but cover all key processes           performed on the platform by          models explained
                         performed via email / outside of                 actions are properly logged and      different systems. Difficult to       performed by analysts and team        users, ability to trace back to all   Real-time audit for all activities performed on the platform by users,
                         audited tools                                    monitored                            extract detail of granular tasks      members                               data changes                          ability to trace back to all data changes.

Scalability              Current system and infrastructure                Limited manual processes,            Only core platform are fully          Systems are all scalable, however     Platform is fully scalable with       Highly scalable solutions used with optimised costs
                         not scalable due to manual                       however legacy solutions limit       scalable, however costs are high      cost to scale is high                 minimal costs for the business        Platform is fully scalable with minimal costs for the business and
                         process, inefficiency and legacy                 the process and functional           due to legacy components                                                    and enabling growth                   enabling growth.
                         solutions                                        scalability

Integration              Systems are integrated via flat                  Minimal integration between          Data integration via batch            API based interfaces and real         API based integration with            Highly integrated systems that allow data sharing between different
                         files or via manual upload of                    systems via batch / files. Several   interfaces, reference data is fully   time interfaces to transfer data      different repository, modular         areas
                         files, different processes are                   manual interfaces and data           utilized in platform and systems      across systems                        architecture, based on                API based integration with different repository, modular architecture,
                         performed in different systems                   upload to extract and process                                                                                    microservices                         based on microservices.

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Conclusion

By moving to a leading                                                                    Establish a proactive AML function        Integrate traditional rule-based       These functions give organisations the
                                                                                          through the use of technology and         solutions with a sophisticated         edge in the fight against financial crime,
position in the Napier AML                                                                drive business by minimising risk         machine learning capability, while     as well as helping to minimise risk and
Maturity Model, ultimately                                                                                                          retaining the ability to explain and   reputational damage.
                                                                                          Put clients firmly at the centre of the   audit every decision
this gives an organisation
                                                                                          AML function - with transactions,
the ability to:                                                                           onboarding, screening and reviews         Give the compliance team the ability
                                                                                          all connected through state-of-the-       to drill down into each transaction
                                                                                          art processes and systems                 and all relevant datapoints related
                                                                                                                                    to clients

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Getting to the next level

Once you have identified                                                     Leaders can use this guide to identify the
                                                                             specific dimensions of AML systems and
your organisation’s                                                          processes that should be given higher
current level of AML                                                         priority for improvement initiatives.

maturity, the model defines
                                                                             Regardless of where your organisation
improvements to help you                                                     stands in its strategic AML maturity, if
move through the next                                                        you are interested in discussing how
                                                                             technology can improve AML performance,
stages of maturity.
                                                                             please contact us on info@napier.ai or visit
                                                                             us on www.napier.ai

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Who is Napier?
                                                                             Our solutions
Napier is a new breed of                                                     We have two solutions - one for              Our products include:                      Our tools dramatically reduce both
                                                                             Anti-Money Laundering (AML) and the          • Transaction Monitoring                   false positives and false negatives and
AML and trade compliance                                                     other for Trade Compliance. Our solutions    • Transaction Screening                    empower compliance teams to make
tech providers.                                                              can be applied to compliance challenges      • Client Screening                         validated decisions with unprecedented
                                                                             in any sector and address every aspect of    • Client Activity Review                   speed and accuracy.
                                                                             AML & TC.                                    • Risk-based Scorecard
Our Intelligent Compliance                                                                                                                                           We have an expert team driving forward
Platform is transforming                                                     All Napier products harness the power of     The platform is extensible and scalable;   our vision for compliance. With over 100
                                                                             AI and can be integrated together into our   developed specifically to adapt to the     years combined experience in compliance,
compliance from legal
                                                                             third-generation compliance platform.        needs of businesses large and small, and   IT and financial services, our expertise in
obligation to competitive                                                                                                 importantly, industry challenges coming    AML is second to none.
edge.                                                                                                                     ahead. It can be delivered via public
                                                                                                                          cloud, private cloud or on premise.        To learn more about the Napier platform,
                                                                                                                                                                     please visit www.napier.ai

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NAPIER.AI

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