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Anti Money Laundering, Data Collection and Reporting • Information Technology Service External Systems Unit • Global Programme against Money Laundering Money Laundering/Terrorist Financing – The World’s Response • Establish a global environment hostile to money laundering and terrorist financing • Implement international standards including the FATF 40+9 recommendations • Establish Financial Intelligence Units around the world • Establish protocols and platforms for sharing intelligence and evidence • Secure technical assistance for countries to implement international standards • Uniform and standard AML platform - desirable Anti-Money Laundering Process Three essential components of an AML/CFT regime: • A functional compliance culture • Functional regulatory bodies – central Bank, SEC, Insurance Regulator etc • An effective financial intelligence unit tasked with: • The above processes ideally should be automated particularly if they involve high data volumes From Start to Finish Brief History – ITS • 2005 – UNODC appointed project manager for EC project in Nigeria • Significant component – provision of IT solutions to EFCC including NFIU • March 2006 UNODC ITS tasked with developing IT solutions • April 2006 – ITS commences developing database and analytical tools for NFIU • June 2006 – XML Schema introduced to Nigerian reporting institutions • October 2006 – CTR database and basic analytical functions installed in NFIU and tested Brief History – GPML • Frequent requests from developing FIUs for IT solutions • Early involvement in Nigeria project including in advisory role to IT component • Potential for goAML beyond the Nigeria project recognized • Simultaneous – work commences on widening the scope of the system beyond Nigeria Current – Future February 07 • Data collection tools completed • Analytical functionality available • Drawing tools phase 1 nearing completion • Rules engine under construction • Profiling tool under construction July 07 • STR system completed • Profiling tool completed • Intelligence file management completed • Workflow system completed • Drawing tools phase 1 completed Current – Future September 2007 • Phase 1 goCASE complete June 2008 • Drawing tools completed • Rule engine and editor completed • Full user documentation in multiple languages (English, French, Spanish, Russian) • goAML (complete suite) VERSION 1.0 READY! July 2008 • Phase 2 goCASE complete goAML – global Operations Anti-Money Laundering • Designed as a modular system to fit the needs of any FIU irrespective of size • from a single computer with a few thousand processes - up to 500 million processes over 5 year period irrespective of file size • Processes and analyzes reports on: - Suspicious transactions - Financial transactions – of any type - List or alert based reports – CFT etc • Fully electronic data collection and dissemination from any source such tax, law enforcement records, immigration service (passenger movement records), property registrar, vehicle registrar etc…. Data Collection Intelligence Data Clean report writer up Ad-hoc Charting and queries and diagramming matching Integration Statistical and/or data reports on acquisition reports from other received and sources processed Intelligence Structured file analysis management (strategic system and tactical) Document Management Profiling (full text search) Task Rule based Assignment analysis and Tracking Workflow System goAML – global Operations Solution Building Blocks Anti-Money Laundering Anti-Money Laundering goAML – Collecting and Managing Information Reporting standard defined: • XML based (world standard format) • Samples available for FI IT Personnel • Exhaustive documentation available Validation application: • Checks for valid XML • All required fields are present • Data types are correct • Ensures reporting entities report in the correct format from day 1 goAML – Gathering and Managing Information Secure website (SSL 512 bit encryption) for: • Creating reporting entities - by the FIU • Creating contacts • Changing contact details - by the reporting entity • Report upload • Report data entry - manually if necessary • Report verification - clean up by system goAML – Gathering and Managing Information • Report History - what reported - accepted/rejected ref number • View uploaded report - Individually • Submission status - accepted/rejected • Common content for any reporting entity - flexible - secure information from FIU - compliance circulars - alerts - name lists goAML – High Volume Analysis • Support analytical and investigation teams with highly sophisticated reporting capabilities. • Visualize large volumes of data to help understand the big picture. • Monitor potentially suspicious accounts. • Reveal patterns and hidden connections. • Create analytical charts manually or automatically. goAML – Collecting, Managing and Analyzing Information Workflow for STR analysis • Tasks and the process diagram are defined by the FIU users - can change to suit their own needs - full visual designer • Task assignment and tracking - within FIU - push or pull reports by e-mail • Integrated reporting - workflow reports - assignments - progress - results goAML – Collecting, Managing and Analyzing Information • Integrated source tracking - tracks externally sourced information - creates bring-ups, reminders etc • Automatic resource scheduling - automatically assigns tasks - monitors workloads - measures outputs/performance • Case feedback integration - Produces standardized feedback - reports as word documents goAML – Collecting, Managing and Analyzing Information • Customizable data gathering templates - standardized format for receipt of information from outside agencies that decides transmission medium (email/fax/post) • Time in flight analysis - Time management measure goAML – Analysis and Targeting Solution • Common user interface across analysis screens - screens look and feel the same - supports multiple languages • Workspace based (keep information through different reporting sessions) - two work spaces available at any one time - previous work automatically saved - supports text, tables, merged tables, pictures goAML – Analysis and Targeting Solution • Analyst can retrieve, filter and re-arrange the data accordingly to his/her needs. - Rearrange data fields - Change grouping - Filter data - Change data sorting - Save layout - Export goAML – Analysis and Targeting Solution • Linking to other screens from current screen • Allows easy comparison of different accounts, persons or entities • Each window acts independent of others • Copy fields or rows • Makes analysis easy • Very easy to learn • All these components have restricted access goAML – Analysis Trails Link charts association charts – transaction flow charts etc • Money and person trails for inbound and outbound transactions • Trail for duplicated addresses, phone numbers and other identification data • Displays: - source and destination displayed as nodes - direction and amount displayed as arrows goAML – Analysis - Pivots • Reports offer many different views of data under analysis • Allows for dynamic user filtering and grouping of related data • Allows for searching for TOP targets - 5/10/50 etc • Flexible data search capability • Simple integration with Excel - excellent for net worth analysis - ease of attachment to intel reports - arrives live so can be manipulated by receiver goAML – Analysis - Intersect • Combines data from two different reports - User chooses the two reports populated with data and the columns to intersect Result is displayed in a completely new window with the intersected data goAML – Information Dissemination • Suspicious activity detected • Open a new case – analysis output attached • goCASE picks this up • Export case to MS-WinWord - Case file remains with FIU - Output in the form of Intel report - Sanitised to the level required by the user goAML - User and role based functions • Management: Is able to check the submissions and the status of reporting entities. - performance measure/compliance • Analyst: Responsible of conducting the analysis, finding suspicious activities and linking to similar-patterned cases where they exist - analysis • Administrator: Allowed to add new user, give/revoke access to screens and different actions. Access to certain actions is dependant on the user’s role! goAML - Security • Username and password required to access applications. • Access can be granted and revoked per: - User - Screen - Certain actions like copy, export etc. • Access to screens and data is logged. • Data partially encrypted in the database. - Encryption level and extent at the discretion of the user goAML - Security • Access to the system generally or to any part of it at the discretion of the user – the user must “open the gate” • UNODC does not hold private key – cannot decipher encrypted data • Rule engine secure • Database and system tools installed on the user’s premises, UNODC has no independent access goAML – System Requirements • Assumes average data load – 500,000 reports per month • Assumes 15 users • Assumes reasonable level of existing infrastructure including security - Mail servers - Local area network - DMZ with 2 firewalls - Anti-spam and anti-virus policy • Provide fully redundant environment - 2 DB Servers - 2 Application servers - Storage area network (SAN) - Backup robot servers - Public key infrastructure certificates (PKI) - 15 high end personal computers (PCs) Approx: $220,000 goAML – Estimated Costs • goAML software package is free of charge • Installation – initial training US$ 80,000 (depending on location – 3 visits x 2 persons) • Annual user license agreement US$ 100,000 - This fee will decrease as more users take up the system - Provides support within working hours in local time zones - Provides ongoing system development - Guarantees one on-site visit per year ____________ US$ 180,000 Breakdown of Costs (Basic installation) • Installation – US$80,000 – Establishment of standard reporting scheme for reporting institutions – Training of reporting institution compliance and IT staff; – Customisation of report formats and forms – Customisation of goAML interfaces to individual user requirements – Migration of existing data to goAML database – Installation of goAML and completion of data migration – Implementation of reporting system – Training of FIU management, analysts and IT personnel – Follow up and troubleshooting Time frame 3 – 6 months depending on existing infrastructure and current operating environment. Breakdown of Costs (Basic installation) Maintenance, support and development fee – US$100,000 per annum • Time zone specific, business hour support by e-mail, phone or fax – provided by regional support centers • Outside business hours support provided from other time zones where language permits • Ongoing, needs based, customization and development. • At least one site visit per annum timed to the requirements of the user • Continuous minor upgrade and patch service • Periodical major upgrades – new releases • Regular regional user group meetings and online forums • Access, where necessary, to the full resources of the ITS Service of UNODC Breakdown of Costs (Standard installation) Initial Deployment/Installation – US$600,000, maintenance and development fee – US$300,000 pa. (Assumes maximum 15 users) • Includes all services of Basic Installation plus: • Site assessment • Skills assessment • Design and supervise build of physical infrastructure • Design and plan full system architecture • Purchase, delivery and installation of all server and storage equipment • Purchase software licenses Breakdown of Costs (Premium installation) Initial Deployment/Installation – US$3,200,000, maintenance and development fee – US$1,200,000 pa. (Assumes maximum 100 users) • Includes all services of Standard Installation plus: • Purchase, delivery and installation of all equipment (full IT infrastructure and telecommunications) • A support team on-site backed up by a development team offsite • Purchase software licenses • Management of maintenance contracts with suppliers • Management of the buildup of the local IT unit with gradual hand over • Full hardware and software upgrades and replacements (3 year cycle) • Project duration (3-5 years) Impossible is not a fact, only an opinion Thank you!
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