Tackling financial crime is never easy, and with plenty of different scenarios thrown at compliance officers each day it’s easy to lose track of what’s working and what’s not.
ComplyAdvantage has created a real-time transaction monitoring game to highlight the difficulties of fighting financial crime. The game challenges you to match the rules and thresholds to the suspicious transactions - to try and ‘Catch Them If You Can!’ Click here to try the game today.
The springboard for creating the game was a series of tumultuous global events triggering a dramatic shift in consumer and criminal behaviour alike, which begs the question: how can your business continue to monitor for suspicious activity?
The game brings to life the challenge that anti-money laundering teams face today. A rise in irregular consumer behaviour caused by the Covid-19 pandemic has made it much harder to discriminate between legitimate activity in a time of uncertainty and illegal transactions.
Criminals focused on finding new opportunities to generate illegal funds are seizing the moment, capitalising on vulnerable demographics such as the elderly. Organised crime groups are targeting ‘money mules’ with fraud schemes against a backdrop of growing unemployment, using individuals who are desperate to earn a living and usually unaware they are moving illicit funds.
Even those whose transaction patterns remain unchanged present a risk, potentially laundering illegitimate earnings at a time when there is limited business taking place. Financial institutions are now on the back foot. They must reassess their risk-based approach to ongoing account monitoring and adjust internal rule-sets to accommodate for new behaviours. For those with inflexible monitoring software it’s a painful process and readjusting once the pandemic passes is likely to be at least as difficult.
Of course it is not just consumers whose behaviour is changing. Businesses are having to cope with the impact of dispersed teams, staff illness, and alert triage. All of whichis having an impact on infrastructure and financial crime prevention, not to mention difficulties that have arisen from having to onboard customers at a distance.
It’s one thing if your business has created an embedded long-distance approach to Know Your Customer (KYC) like the fintech challenger banks, but for many of the CMA9 and other legacy players, it presents an extra challenge to onboarding customers with security. And as tempting as it may be to rush ahead, the risk of temporarily deactivating less efficient alerts or adjusting policies to give analysts additional time still needs to be managed through a clear risk assessment and documented governance.
Financial institutions need to stay agile and be equipped to make quick changes to their systems. It is not enough to simply adjust thresholds, as you can see for yourself in the game. Automation lets firms collect and analyse the vast amounts of data relevant to their compliance obligations, identifies suspicious transactions quickly, and expedites thick-file suspicious activity reports to financial authorities. Financial institutions need to keep an open dialogue with regulators, communicate changes to transaction-monitoring systems, and maintain a sufficient audit on investigation outputs if they are to come out of this with a more robust approach to transaction risk management that can handle the crises of the 21st century.
Come play the game and try to ‘Catch Them If You Can!’