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Anti-Money Laundering Case Studies
                                                                               David Stewart, CAMS
                                                                           Director, Financial Crimes
                                                                                       SAS Americas

Copyright 息 2006, SAS Institute Inc. All rights reserved.
Session Overview

             SAS Anti-Money Laundering速 Customers
                                  Sovereign Bank
                                  BB&T
                                  Bank of America


             AML Enforcement Horror Story
                                  Washington Mutual




Copyright 息 2006, SAS Institute Inc. All rights reserved.
About Sovereign Bank

                                                   17th largest banking institution in the
                                                   United States
                                                   $ 90 Billion financial institution
                                                   800 branches in 9 states
                                                   Principal markets in Northeast United
                                                   States
                                                   Regulated by Office of Thrift Supervision
                                                   NYSE: SOV



                                                   Source: www.sovereignbank.com as of March 14, 2007
Copyright 息 2006, SAS Institute Inc. All rights reserved.
High Risk Monitoring




                                                            Investigation




Copyright 息 2006, SAS Institute Inc. All rights reserved.
Unique Characteristics

                                      Financial Intelligence Unit shares Data w/Loss
                                      Operations (Fraud) department
                                      Unique Text String Scenarios
                                      Business Analyst Function
                                      3 million accounts monitored per night
                                      30 Analysts / Investigators
                                      Supervised Routing
                                      ASP/Hosted Environment


Copyright 息 2006, SAS Institute Inc. All rights reserved.
Sovereign Best Practices

                                      Interactive Risk List Management
                                      Advanced Analytic Techniques
                                          Near Neighbor Detection
                                          Link Analysis
                                      Scenario Tuning
                                      AML Data for Opportunity Management




Copyright 息 2006, SAS Institute Inc. All rights reserved.
BB&T
                                   Ninth largest U.S. financial services holding
                                   company
                                   Total assets $122 billion as of 08/01/07
                                   In the past 16 years, BB&T has acquired
                                        60 community banks and thrifts
                                        73 insurance agencies
                                        25 non-bank entities
                                   Primary market segments are comprised of 50%
                                   retail and 50% commercial



Copyright 息 2006, SAS Institute Inc. All rights reserved.
Copyright 息 2006, SAS Institute Inc. All rights reserved.
Unique Characteristics

                                      Transaction Monitoring team taking over
                                      Currency Transaction Reporting processes
                                      First Customer to incorporate KYC scores into
                                      the monitoring process
                                      10 million accounts monitored per day
                                      10 Lines of business monitored
                                      30 Analysts / Investigators




Copyright 息 2006, SAS Institute Inc. All rights reserved.
Best Practices

                                      Monitor ALL transactions through SAS AML
                                      Strong Executive Sponsorship
                                      Monitor Commercial accounts monthly
                                      Scenario Analysis & Tuning
                                      Manage Risk Lists for EDD




Copyright 息 2006, SAS Institute Inc. All rights reserved.
About Bank of America

                                      #1 Retail Bank in North America
                                      Have a relationship with 1 in 3 US Households
                                      $ 1.5 Trillion in Assets Under Management
                                      65 million customers
                                      Retail, Commercial, Private Banking, Global
                                      Corporate Investment Bank, Trust




Copyright 息 2006, SAS Institute Inc. All rights reserved.
Unique Characteristics

                                      30 million daily transactions
                                      Monitor over 1 billion transactions per night
                                      Investigations generated by
                                          SAS Transaction Monitoring
                                          Surveillance
                                          Investigation
                                          Field Alerts / Manual
                                      45 Analysts / Investigators
                                      25 +/- Scenarios

Copyright 息 2006, SAS Institute Inc. All rights reserved.
Best Practices

                                      Scaling large data volumes in Teradata
                                      Business Intelligence Layer
                                          Reduction
                                          Triage
                                      Team of SAS Business Analysts
                                      Hit Rates
                                      In database monitoring




Copyright 息 2006, SAS Institute Inc. All rights reserved.
Washington Mutual

                                      $ 355 billion in Assets Under Management
                                      Regulated by Office of Thrift Supervision
                                      Cease & Desist Order




Copyright 息 2006, SAS Institute Inc. All rights reserved.
Deficient Processes

                                      Failed to file SARs & CTRs in timely manner
                                      Controls for SAR decisions
                                      CIP / Risk Scoring
                                      Measuring Effectiveness of Monitoring
                                      Aggregating Cash Transactions
                                      Identifying Customer Relationships- Networks




Copyright 息 2006, SAS Institute Inc. All rights reserved.
Questions & Answers

                                  David Stewart, CAMS

                                  Director, Financial Crimes & Compliance

                                  SAS Americas

                                  SAS Institute Inc.

                                  T-4, SAS Campus Drive

                                  Cary, North Carolina 27513

                                  United States

                                  919.531.6250

                                  david.stewart@sas.com


Copyright 息 2006, SAS Institute Inc. All rights reserved.
Copyright 息 2006, SAS Institute Inc. All rights reserved.

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  • 1. Anti-Money Laundering Case Studies David Stewart, CAMS Director, Financial Crimes SAS Americas Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 2. Session Overview SAS Anti-Money Laundering速 Customers Sovereign Bank BB&T Bank of America AML Enforcement Horror Story Washington Mutual Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 3. About Sovereign Bank 17th largest banking institution in the United States $ 90 Billion financial institution 800 branches in 9 states Principal markets in Northeast United States Regulated by Office of Thrift Supervision NYSE: SOV Source: www.sovereignbank.com as of March 14, 2007 Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 4. High Risk Monitoring Investigation Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 5. Unique Characteristics Financial Intelligence Unit shares Data w/Loss Operations (Fraud) department Unique Text String Scenarios Business Analyst Function 3 million accounts monitored per night 30 Analysts / Investigators Supervised Routing ASP/Hosted Environment Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 6. Sovereign Best Practices Interactive Risk List Management Advanced Analytic Techniques Near Neighbor Detection Link Analysis Scenario Tuning AML Data for Opportunity Management Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 7. BB&T Ninth largest U.S. financial services holding company Total assets $122 billion as of 08/01/07 In the past 16 years, BB&T has acquired 60 community banks and thrifts 73 insurance agencies 25 non-bank entities Primary market segments are comprised of 50% retail and 50% commercial Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 8. Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 9. Unique Characteristics Transaction Monitoring team taking over Currency Transaction Reporting processes First Customer to incorporate KYC scores into the monitoring process 10 million accounts monitored per day 10 Lines of business monitored 30 Analysts / Investigators Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 10. Best Practices Monitor ALL transactions through SAS AML Strong Executive Sponsorship Monitor Commercial accounts monthly Scenario Analysis & Tuning Manage Risk Lists for EDD Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 11. About Bank of America #1 Retail Bank in North America Have a relationship with 1 in 3 US Households $ 1.5 Trillion in Assets Under Management 65 million customers Retail, Commercial, Private Banking, Global Corporate Investment Bank, Trust Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 12. Unique Characteristics 30 million daily transactions Monitor over 1 billion transactions per night Investigations generated by SAS Transaction Monitoring Surveillance Investigation Field Alerts / Manual 45 Analysts / Investigators 25 +/- Scenarios Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 13. Best Practices Scaling large data volumes in Teradata Business Intelligence Layer Reduction Triage Team of SAS Business Analysts Hit Rates In database monitoring Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 14. Washington Mutual $ 355 billion in Assets Under Management Regulated by Office of Thrift Supervision Cease & Desist Order Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 15. Deficient Processes Failed to file SARs & CTRs in timely manner Controls for SAR decisions CIP / Risk Scoring Measuring Effectiveness of Monitoring Aggregating Cash Transactions Identifying Customer Relationships- Networks Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 16. Questions & Answers David Stewart, CAMS Director, Financial Crimes & Compliance SAS Americas SAS Institute Inc. T-4, SAS Campus Drive Cary, North Carolina 27513 United States 919.531.6250 david.stewart@sas.com Copyright 息 2006, SAS Institute Inc. All rights reserved.
  • 17. Copyright 息 2006, SAS Institute Inc. All rights reserved.