Balance Needed for AML Sanctions - A Response.

I read with interest Douglas Sloan’s comments regarding the challenges of complying with AML and Sanction Regulations.

There are systems on the market now, that will automatically review many data sources to complete a positive AML verification of an Individual and a Business – SmartSearch, for example, will search up to one billion data records and on average find over 6 independent data sources that will confirm an individual’s identity.

Negative Sanction & PEP screening is more hazardous as new Sanctions are being applied to Individuals and Businesses all the time, so it is like trying to hit a moving target. This is further compounded by the fact that these are only name matches, so “John Smith” on a Sanction List will get lots of innocent matches. As a consequence in the vast majority of cases these will be “false positive” matches but they inevitably consume lots of compliance resource to confirm their false positive status.

At SmartSearch we have automated most of this space. We host a version of the Dow Jones “Watch List” which has over 1,000 Sanction List data sources changing daily, so we update this database every day and do a complete re-build at the end of each month. The net outcome is we pick up all Sanction List changes on a daily basis. We then use the very latest data to check new accounts and monitor existing accounts on a daily basis. Where a Sanction match occurs, we launch Automated Enhanced Due Diligence to check key data elements between the matched records to confirm the “false positive”.   This status is then flagged on the appropriate AML record in the SmartSearch System.   At the same time the system generates an email alert to the Compliance Team/MLRO notifying them of the Sanction match.   On the very rare occasions where the Sanction match is “real” then SmartSearch collates automatically the biography, adverse media and pictorial evidence to enable the Compliance Team to start their own manual verification with a realm of start up data.

These are all automated processes; a complete Business AML check takes less than 4 minutes and an Individual AML check takes less than a minute, both include full Sanction and PEP screening with ongoing monitoring – Job Done!!

Our Client’s Compliance Departments now have plenty of time to enjoy their annual holiday entitlement and time to attend to other pressing issues.