Posted by & filed under AML General, Negative News.

easy-aml-complianceAt my twin daughters’ 7th grade back to school night last week I was forced to relive my horror of Algebra 1.

As the parents walked into the classroom, the teacher handed us an index card and told us to complete the problem on the board.  “Show your work or no credit, and your kids will be the ones grading,” she said.

The next day my daughters let me know that I got zero credit.  It was as though I was sitting back in 1983, when I first realized a career requiring math skills was probably not in my future.

Math isn’t the only place though where we must show our work.  Turns out AML requires the same thing.

In fact, “showing your AML work” aka, “documenting files” is where analysts and investigators spend most of their time.

Excited AML executivesDocumentation is critical to maintain strong compliance.  However, documenting work is inefficient and detracts from more important tasks.  This is particularly the case when it comes to documenting negative news searching and results.

Fortunately, all negative news documentation can now be automated, freeing up investigators to spend more time on work that matters.

Why We Document AML Work

Just like in Algebra, AML investigators must document what they do so that others (managers, auditors, regulators) can assess whether decisions, like filing a SAR, are supported by sound reasoning.  If an EDD analyst decides to recommend raising a customer’s risk rating from “moderate risk” to “high risk,” because there is an article reporting the customer is entering the (legal) marijuana retail business, having a copy of that article in the file is essential.

AML analysts and investigators also document their work to prove they did work in the first place.   As every AML analyst, investigator, and manager knows, documentation requirements eat up enormous time.  As much as 50% of AML work is copying, cutting, pasting, taking screen shots, and creating PDF’s.

This time would be better spent analyzing more alerts, investigating more cases, and conducting more EDD reviews.

Documenting AML Work Is Monotonous and Slow

Let’s look at how many banks require investigators to document negative news searching.

  • Investigators are often required to show evidence of what name they searched. If the case is about Troy Bolton, they take a screen shot showing “Troy Bolton” in the search bar. Some banks also require investigators capture any search terms or search strings they use to better target their searches, meaning another screen shot.
  • Then there is a screen shot of results, or in the case of Google, a screen shot of a portion of the first page of results. This is so a reviewer or auditor sees that a search was conducted and something was found.  Of course, no-one takes a screen shot of the 50,000 results Google returns.  But why not?  This screen shot is meant to show whether something relevant or not was found, so why only show fewer than 10 results?
  • If an investigator decides to open and read any of the results, he or she will then take another screen shot of what they read. This makes sense of course since these results will often support the investigator’s decision about whatever action they recommend (filing a SAR for example).
  • Interestingly many AML departments require investigators document their review of results that end up not being relevant. For those that must do this, you know the pain.  Proving the negative is becoming the norm in AML.

Doing this over and over again, all day long takes a lot of time and is inefficient.  What is the value of that time and how could it be better spent?

Documenting AML Work Is Now Simple and Fast

In 2017 computers can complete monotonous human tasks.  For AML analysts and investigators this means negative news documentation where copying, cutting, pasting, and screen shots are no longer needed!

Reducing inefficiency, improving investigations, and increasing output of every AML worker is a shared goal.  This is now achievable.

Showing your work is a critical part of AML.  It should be easy to do.

If only Algebra was.  That problem I had to solve was this:  2(x-5) = -16.  Remember, show your work.


This is the fourth post in a series.  See part 1,  part 2, and part 3.

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