Scaling FATCA’s Data
Mountain
Technologies and best practices to
streamline data collection, reporting
and monitoring
Thur...
Ron King
Chief AML Officer
Scotiabank
Toronto
Allen Love
SVP, BSA Officer and Deputy Global AML Officer
TD Bank
Philadelphia
Kelvin Dickenson
Global Risk Management Solutions
D&B
New York
Ed Sander
Global VP and General Manager, AML Solutions
NICE Actimize
New York
What We’re Seeing In the Market
• Focus is split on KYC and tax withholding
– USFIs forced to act as tax withholding agent...
Areas Impacted by FATCA Regulation
FATCA Account Identification is Complex
Business Challenges to Think About
• Avoiding regulatory and reputational impacts
– Legal & financial penalties plus reput...
FATCA Requires Comprehensive Review
• Review required for individual
and entity customers:
What To Look For in a FATCA Solution
Data Management: Best Practices
• Data capture: “Simplify”
– Form-based with dynamic Q&A capability
– Integration with on-...
Issues Detection: Best Practices
• Data cleansing and enrichment: “Identify”
– Customer identity discrepancies
– US addres...
Investigations: Best Practices
• Automated and manual workflows
– Letter creation/document request and response
– IRS requ...
Documentation Management: Best Practices
• Document capture: “Single-Point-of-Access”
– Associate documents with customer ...
Leverage CDD Investments for FATCA
Customer Due Diligence
– A Cornerstone of Your
AML Program

FATCA
Alignment with CDD

...
FATCA & CDD Common Capabilities
FATCA

CDD

Customer
Verification

Data
Collection

Customer
Risk Ranking

Document
Reques...
Data Considerations for IGA/non-IGA
• Flexibility in your technology solution
– You’ll need to run different modules & bus...


Final Thoughts –


FATCA

CDD Benefits

• Streamline existing processes for Account ID
– Consolidate and enrich data a...
Your
Questions
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Scaling FATCA’s Data Mountain – Technologies and best practices to streamline data collection, reporting and monitoring

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Scaling FATCA’s Data Mountain – Technologies and best practices to streamline data collection, reporting and monitoring

  1. 1. Scaling FATCA’s Data Mountain Technologies and best practices to streamline data collection, reporting and monitoring Thursday, February 6, 2014 | 10:30 – 11:30 AM Speakers: Kelvin Dickenson, Ron King, Allen Love, Ed Sander
  2. 2. Ron King Chief AML Officer Scotiabank Toronto
  3. 3. Allen Love SVP, BSA Officer and Deputy Global AML Officer TD Bank Philadelphia
  4. 4. Kelvin Dickenson Global Risk Management Solutions D&B New York
  5. 5. Ed Sander Global VP and General Manager, AML Solutions NICE Actimize New York
  6. 6. What We’re Seeing In the Market • Focus is split on KYC and tax withholding – USFIs forced to act as tax withholding agents – FFIs revisiting customer due diligence programs • Data availability & quality are huge concerns • Injecting FATCA ID w/in existing CDD processes • Regulation uncertainties still continue – IGA network continues to evolve
  7. 7. Areas Impacted by FATCA Regulation
  8. 8. FATCA Account Identification is Complex
  9. 9. Business Challenges to Think About • Avoiding regulatory and reputational impacts – Legal & financial penalties plus reputational risk • Complex regulation  significant business change – Overhauls ID of customers & beneficial ownership • FATCA compliance > huge operational & IT impact • Data quality as lever to better customer insight – New paradigm for managing customer information • Reality of future “FATCA-like” regulation
  10. 10. FATCA Requires Comprehensive Review • Review required for individual and entity customers:
  11. 11. What To Look For in a FATCA Solution
  12. 12. Data Management: Best Practices • Data capture: “Simplify” – Form-based with dynamic Q&A capability – Integration with on-boarding systems • Data consolidation: “Complete 360 View” – Identity verification details & related account info. – Aggregate customer balance over multiple accounts • Data enrichment: “Validate & Verify” – Auto-population of missing data; 3rd Party callouts
  13. 13. Issues Detection: Best Practices • Data cleansing and enrichment: “Identify” – Customer identity discrepancies – US address validation • IRS indicia detection: “Manage Change” – US account identification (pre-existing / new) – US ownership identification (pre-existing / new) • Tracking and review: “Monitor” – Recalcitrant account status; Customer status changes – Documentary tracking
  14. 14. Investigations: Best Practices • Automated and manual workflows – Letter creation/document request and response – IRS request management • FATCA customer account classification – Identification of passive NFFEs* and beneficial ownerships • Complete customer record – Customer/entity profile info.; indicia alert details – Shows related accounts/entities and ownership *Non-Financial Foreign Entities
  15. 15. Documentation Management: Best Practices • Document capture: “Single-Point-of-Access” – Associate documents with customer record – Centralize documentary account / reference info. – Ability to Integrate w/document management systems • Document tracking: “Flag Changes” – Manage & track document expiration (passport, etc.) • Email integration: “Prepare for Audits” – Integrate emails/attachments as part of workflow – Ability to audit email exchanges
  16. 16. Leverage CDD Investments for FATCA Customer Due Diligence – A Cornerstone of Your AML Program FATCA Alignment with CDD  Knowing / understanding a customer  Collection of customer information  Defining the acceptable business context  Customer classification  Understanding ongoing customer relationship  Tracking of documentation and evidentiary information  Periodic reporting to regulators  Ongoing review and verification of customers
  17. 17. FATCA & CDD Common Capabilities FATCA CDD Customer Verification Data Collection Customer Risk Ranking Document Request & Response Customer Classification Anticipatory Behaviour Capture Indicia Detection Models Documentary Tracking Customer Risk Detection Models FATCA Workflows Ongoing Review Periodic Reporting Due Diligence Workflows
  18. 18. Data Considerations for IGA/non-IGA • Flexibility in your technology solution – You’ll need to run different modules & business rules – Different IGA agreements will require different FATCA-related business logic and data elements • Real-time services that are FATCA specific – Data verification across jurisdictions – US IRS indicia checks that are automated – FATCA determination status that is ongoing
  19. 19.  Final Thoughts –  FATCA CDD Benefits • Streamline existing processes for Account ID – Consolidate and enrich data across multiple sources • Increase productivity and operational efficiency – Simplify applicant and ongoing client review – Automate document capture and reporting process – FATCA requires flexibility and extensibility in CDD • Leverage to improve customer-centric approach – Centralized, comprehensive “single-customer-view”
  20. 20. Your Questions

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