The “Summit” View of AML Risk – Using “BI” to Reach the Top
On one of my recent weekends, I went hiking in the Hudson Valley, not too far away from New York City. The six-mile trail had us slowly climbing towards the summit of Hook Mountain and presented us with a series of sharp turns along the way. It wasn’t until we reached the very top that we were able to finally catch our breath and admire the wonderful view of the surrounding area.
In a way, getting the full view of your anti-money laundering risk is very much like hiking – but usually it is more like hiking in the “16 mile moderate-to-strenuous hike” kind of way, not in the “1 mile, easy walk around the lake” kind of way. Just like my trek up Hook Mountain, it’s challenging to get to the summit – that full view –. As you ascend, you often don’t see your goal along the way, and you will probably encounter a series of sharp turns. But once you finally get to the top—and achieve your objective — the view is amazing.
In the AML world, many regulators have recently been putting the pressure on financial services organizations to “connect the dots” and demonstrate their understanding of the risk across the organization. This is the “summit” view, but getting there can be arduous and there are many elements which need to be considered, especially when you look to leverage Business Information (“BI”) tools to get there.
First, from that high level view, you need to consider what data elements are critical to be presented. It is easy to get carried away with the flexibility and capabilities of many of the newest BI tools, but sometimes “less” is “more”. The focus should be on presenting the most important metrics and putting them in context by showing a trend. Is a 10% SAR-to-alert ratio good or bad? Well, it depends on the historical perspective, understanding if the ratio has gone up or down in comparison to previous reporting periods. Putting information in context can also mean identifying the specific business areas – specific geographies, line of businesses or departments – that have experienced the greatest level of change.
Second, you need to always keep in mind that the BI tool will present you with information, while considering what else is going on in the organization in order to put the change into business context. Is a 2 percent increase in SAR filing satisfying? Well, it depends on what else has happened. Did your organization recently go through a tuning exercise? Were new products introduced? New verticals? What other material changes had occurred?
Third, think about the way down. Certain users will use the BI tool to “drill down” in order to get a better understanding of an issue, so they need to be able to see that detailed view across different dimensions, such as business units or issue types. In hiking, coming down from the summit is usually easier than going up, but in the AML and BI space, climbing down might actually be more challenging. When you design a report think about the summit view, but also keep in mind how users will want to interact with it to get a more detailed view.
Lastly, be thoughtful about the type of users who will interact with the report. Mind which data you’re giving them access to, and which is it appropriate for them to see. Much of the information in the AML space is confidential and sensitive, and the potential reputational impact of having this information leaked could be devastating. It might be more work to design different forms that show similar information, or maintain a strict level of permissions around the data, but it is usually worth the effort if it provides more security and control around your information.
So you see, designing a BI report could be a bit like a hike – but at least it will keep your organization in shape!