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Surfing
Uncertainty
To Confront
Terrorism
Financing
Thomas M. Obermaier
FFE KeynoteAddress
June 19, 2018
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Hardest Problem in RegTech/FinTech to Solve
2
Rife with Uncertainty
Impossible to predict
Lack of Financial
Dependency
Indistinguishable
from Ordinary
Activity
HalfThe Story
Local Scale Constantly Morphing
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Organizational Costs
“Planning”
• Maintain Infrastructure
• Day-to-day (salaries, subsistence)
• Communication
• Training
• Travel
• Logistics
• Charitable Support
• Mass Media Distribution
Direct Cost of Attacks
“Use”
• Vehicles
• Surveillance Means
• Maps
• IED Components
• Target Lodging
TraditionalApproach: The “Obvi”
3
TwoTypes ofTerrorism Financing Needs
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
TraditionalApproach: The “Obvi”
4
Three Categories ofTerrorism Financing
The Raise Raising capital to cover planning and use phases, as well as broad
organization support, where appropriate.
• Charities
• Illegal criminal activity (fraud, narcotics, theft, robbery,
kidnapping)
• Legitimate business (cash intensive businesses, small retail,
restaurants, locksmith, construction)
• Self (salary, welfare)
TheTransfer Moving It
• FX transactions
• Formal financial sector
• FinTech
• Trade-related
• Cash couriers
• Hawalas (ARS)
Use Seemingly limitless
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Traditional ApproachTo Disruption
5
Raising
Transfer
Use
FATF Funnel
Reliance on
“Special
Designation”
Government
Lists
Traditional CTF Approach
Primary focus
on what we knew
• Global Orgs
• Global
Funding
• Global Scale
Curiously, Use (which in the end is
everything and the most difficult to
find) was given third priority
1. Groupe d’action financiere. Terrorist Financing. 29
February 2008
1
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Paradigm has Shifted
6
Use
Transfer
Raise
Current Reality: Use Is Everything
Primary Local
Ordinary Means
Plain Sight
Exceeding Low Cost
More Self-Funding
Old School ≠ Nu Skool
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
What To Do?
7
This is Really Hard
Better as technology and
data science improve
High social impact
Microscopically
Infrequent
Indistinguishable
From Ordinary
Activity
At Best, Know
HalfThe Story
We Are Not An
Intelligence or
Law
Enforcement
Agency
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
CTF Challenge
8
Finding a Needle in a Pile of Needles
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Focus On Seen and Unseen
9
Embrace the certainty
Surf the uncertainty
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
The Seen
10
Embrace the certain
▪ Specific designation
Government Lists
▪ Transfers to/from
Terrorist List
▪ Charitable transfers
▪ Adverse Media on
clients and
transferees
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
The Unseen
11
Surf the Uncertainty
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Surfing Uncertainty
12
Teach Machines Cognitive Prediction
How Humans Think
1
1. Clark, Andy. Surfing Uncertainty: Prediction , Action and
The Embodied Mind. Oxford University Press, 2015. ISBN:
9780190217013.
Learn from both
experience and
simulation
Mathematical
prediction based on
experience (actual &
simulation)
Predictive
Action
Embodied Mind
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Building Cognitive Prediction
13
• Algo Building
• “Straw that broke
the camels back”
• Contextual,
Transactional,
Sequential data
sensitive
• Comprehensive
Historical Scope
• Incidence Focused
• Key Common
Markers
• Trend Development
• Both internally sourced transactional data
and externally sourced contextual and
sequential
• One hand tied behind our backs
• Cautionary tale on external sources
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
BuildingA Cognitive Predictive Engine:
Focus onThree Levels
14
Transactional
Contextual
Sequential
Transactional
Contextual
Sequential
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Public Domain PredictiveVariables
15
Manchester 2017 ✓ ✓ ✓ ✓
London 2017 ✓ ✓ ✓
Brussels 2016 ✓ ✓ ✓ ✓ ✓ ✓
Nice 2016 ✓ ✓ ✓ ✓ ✓ ✓
Berlin 2016 ✓ ✓ ✓ ✓ ✓ ✓
Paris 2015 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Paris 2015 ✓ ✓ ✓ ✓ ✓ ✓
London 2012 ✓ ✓ ✓ ✓
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
PredictiveVariables & Sourcing
16
Location: Residence or work address in Terrorism Vulnerability Area ("TVA")
Transactional
Contextual
Media – Reported
terrorism arrests via
Postal Code (TVA Index),
Public records
Government Reports
Funding
Source:
Payments to/from designed Alias Charities non-salary or divided “Location Payments”
Contextual
Transactional
Designated Alias Charities
Media
Government Reports
Employment:
Employed in a Terrorism Vulnerable Business (“TVB”) – a business TVA or one reported terrorist
used before
Contextual
Transactional
Media
Government Reports
Ownership: Owning a TVB, receiving payments from a TVB
Contextual
Transactional
Media
Government Reports
Criminal
History:
Reported arrests or allegations involving immigration, petty theft, financial crime, kidnapping,
etc. Terrorist Vulnerable History (“TVH”)
Contextual
Media (publicly reported)
Public records (where
available)
Rumored
Associates:
Rumored to be specifically designated terrorist, an associate or a terrorist organization or an
acquaintance or a TVP person
Contextual
Media
Government Reports
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
PredictiveVariables & Sourcing
17
Event Mass event – sport, concert, political, etc.
Contextual
Sequential
Event Aggregators
Media
Travel: Two levels: travels to a known terrorist hub (“TH”) or recent travel outside a (“TVA”)
Transactional
Contextual
Sequential
Transactional
Media
Government Reports
Lodging:
Recent lodging through hotel aggregators or on line residence distributors (Airbnb,
Booking.com, Home Away)
Transactional
Contextual
Sequential
Transactional
Media
Government Reports
Transport: Recent car hires – especially multiple in one name or in associates name
Transactional
Contextual
Sequential
Transactional
Media
Government Reports
Means Transport, fertilizer, bleach, vests, jackets, sporting gear, luggage
Transactional
Contextual
Sequential
Transactional Data
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Terrorism Hubs MediaWord Cloud
18
AllTime
May 2018Last 60 Days
2018
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
TerroristVulnerable Areas
Followfield (Manchester 2017
Besston (London 2005)
Yorkshire (London 2005)
Selly Oak, Birmingham (London 2005)
Hyde Park, Leeds (London 2005)
Thornhill (London 2005)
Holbeck (2005)
Molenbeck (Paris, 2015, Brussels 2015)
Courcouronnes (Paris 2015)
Lepros,Turkey (Paris 2015)
Plaistow (London 2017)
Dagenham (London 2017)
TerrorismVulnearble Businesses
Restaurants
Locksmiths
Handyman
Construction
Uber
Newsstands
Local Groceries
Deliverers
Using Media to Find Contextual Examples
19
www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening
Location
Funding Source
Employment
Ownership
Priors
RumouredAssociate
Events
Travel
Lodging
Transport
Cognitively PredictiveTerrorist Financing
20
Means
Use Prediction
Sequential
Contextual
TransactionalTransactional

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Surfing Uncertainty To Confront Terrorism Financing

  • 1. Surfing Uncertainty To Confront Terrorism Financing Thomas M. Obermaier FFE KeynoteAddress June 19, 2018
  • 2. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Hardest Problem in RegTech/FinTech to Solve 2 Rife with Uncertainty Impossible to predict Lack of Financial Dependency Indistinguishable from Ordinary Activity HalfThe Story Local Scale Constantly Morphing
  • 3. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Organizational Costs “Planning” • Maintain Infrastructure • Day-to-day (salaries, subsistence) • Communication • Training • Travel • Logistics • Charitable Support • Mass Media Distribution Direct Cost of Attacks “Use” • Vehicles • Surveillance Means • Maps • IED Components • Target Lodging TraditionalApproach: The “Obvi” 3 TwoTypes ofTerrorism Financing Needs
  • 4. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening TraditionalApproach: The “Obvi” 4 Three Categories ofTerrorism Financing The Raise Raising capital to cover planning and use phases, as well as broad organization support, where appropriate. • Charities • Illegal criminal activity (fraud, narcotics, theft, robbery, kidnapping) • Legitimate business (cash intensive businesses, small retail, restaurants, locksmith, construction) • Self (salary, welfare) TheTransfer Moving It • FX transactions • Formal financial sector • FinTech • Trade-related • Cash couriers • Hawalas (ARS) Use Seemingly limitless
  • 5. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Traditional ApproachTo Disruption 5 Raising Transfer Use FATF Funnel Reliance on “Special Designation” Government Lists Traditional CTF Approach Primary focus on what we knew • Global Orgs • Global Funding • Global Scale Curiously, Use (which in the end is everything and the most difficult to find) was given third priority 1. Groupe d’action financiere. Terrorist Financing. 29 February 2008 1
  • 6. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Paradigm has Shifted 6 Use Transfer Raise Current Reality: Use Is Everything Primary Local Ordinary Means Plain Sight Exceeding Low Cost More Self-Funding Old School ≠ Nu Skool
  • 7. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening What To Do? 7 This is Really Hard Better as technology and data science improve High social impact Microscopically Infrequent Indistinguishable From Ordinary Activity At Best, Know HalfThe Story We Are Not An Intelligence or Law Enforcement Agency
  • 8. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening CTF Challenge 8 Finding a Needle in a Pile of Needles
  • 9. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Focus On Seen and Unseen 9 Embrace the certainty Surf the uncertainty
  • 10. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening The Seen 10 Embrace the certain ▪ Specific designation Government Lists ▪ Transfers to/from Terrorist List ▪ Charitable transfers ▪ Adverse Media on clients and transferees
  • 11. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening The Unseen 11 Surf the Uncertainty
  • 12. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Surfing Uncertainty 12 Teach Machines Cognitive Prediction How Humans Think 1 1. Clark, Andy. Surfing Uncertainty: Prediction , Action and The Embodied Mind. Oxford University Press, 2015. ISBN: 9780190217013. Learn from both experience and simulation Mathematical prediction based on experience (actual & simulation) Predictive Action Embodied Mind
  • 13. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Building Cognitive Prediction 13 • Algo Building • “Straw that broke the camels back” • Contextual, Transactional, Sequential data sensitive • Comprehensive Historical Scope • Incidence Focused • Key Common Markers • Trend Development • Both internally sourced transactional data and externally sourced contextual and sequential • One hand tied behind our backs • Cautionary tale on external sources
  • 14. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening BuildingA Cognitive Predictive Engine: Focus onThree Levels 14 Transactional Contextual Sequential Transactional Contextual Sequential
  • 15. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Public Domain PredictiveVariables 15 Manchester 2017 ✓ ✓ ✓ ✓ London 2017 ✓ ✓ ✓ Brussels 2016 ✓ ✓ ✓ ✓ ✓ ✓ Nice 2016 ✓ ✓ ✓ ✓ ✓ ✓ Berlin 2016 ✓ ✓ ✓ ✓ ✓ ✓ Paris 2015 ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ Paris 2015 ✓ ✓ ✓ ✓ ✓ ✓ London 2012 ✓ ✓ ✓ ✓
  • 16. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening PredictiveVariables & Sourcing 16 Location: Residence or work address in Terrorism Vulnerability Area ("TVA") Transactional Contextual Media – Reported terrorism arrests via Postal Code (TVA Index), Public records Government Reports Funding Source: Payments to/from designed Alias Charities non-salary or divided “Location Payments” Contextual Transactional Designated Alias Charities Media Government Reports Employment: Employed in a Terrorism Vulnerable Business (“TVB”) – a business TVA or one reported terrorist used before Contextual Transactional Media Government Reports Ownership: Owning a TVB, receiving payments from a TVB Contextual Transactional Media Government Reports Criminal History: Reported arrests or allegations involving immigration, petty theft, financial crime, kidnapping, etc. Terrorist Vulnerable History (“TVH”) Contextual Media (publicly reported) Public records (where available) Rumored Associates: Rumored to be specifically designated terrorist, an associate or a terrorist organization or an acquaintance or a TVP person Contextual Media Government Reports
  • 17. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening PredictiveVariables & Sourcing 17 Event Mass event – sport, concert, political, etc. Contextual Sequential Event Aggregators Media Travel: Two levels: travels to a known terrorist hub (“TH”) or recent travel outside a (“TVA”) Transactional Contextual Sequential Transactional Media Government Reports Lodging: Recent lodging through hotel aggregators or on line residence distributors (Airbnb, Booking.com, Home Away) Transactional Contextual Sequential Transactional Media Government Reports Transport: Recent car hires – especially multiple in one name or in associates name Transactional Contextual Sequential Transactional Media Government Reports Means Transport, fertilizer, bleach, vests, jackets, sporting gear, luggage Transactional Contextual Sequential Transactional Data
  • 18. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Terrorism Hubs MediaWord Cloud 18 AllTime May 2018Last 60 Days 2018
  • 19. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening TerroristVulnerable Areas Followfield (Manchester 2017 Besston (London 2005) Yorkshire (London 2005) Selly Oak, Birmingham (London 2005) Hyde Park, Leeds (London 2005) Thornhill (London 2005) Holbeck (2005) Molenbeck (Paris, 2015, Brussels 2015) Courcouronnes (Paris 2015) Lepros,Turkey (Paris 2015) Plaistow (London 2017) Dagenham (London 2017) TerrorismVulnearble Businesses Restaurants Locksmiths Handyman Construction Uber Newsstands Local Groceries Deliverers Using Media to Find Contextual Examples 19
  • 20. www.rdc.comRDC © 2018 - All Rights ReservedSmarter Screening Location Funding Source Employment Ownership Priors RumouredAssociate Events Travel Lodging Transport Cognitively PredictiveTerrorist Financing 20 Means Use Prediction Sequential Contextual TransactionalTransactional