0122 02SAS

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0122 02SAS

  1. 1. Anti-Money Laundering Case Studies David Stewart, CAMS Director, Financial Crimes SAS AmericasCopyright © 2006, SAS Institute Inc. All rights reserved.
  2. 2. Session Overview SAS Anti-Money Laundering® Customers • Sovereign Bank • BB&T • Bank of America AML Enforcement “Horror Story” • Washington MutualCopyright © 2006, SAS Institute Inc. All rights reserved.
  3. 3. About Sovereign Bank 17th largest banking institution in the United States $ 90 Billion financial institution 800 branches in 9 states Principal markets in Northeast United States Regulated by Office of Thrift Supervision NYSE: SOV Source: www.sovereignbank.com as of March 14, 2007Copyright © 2006, SAS Institute Inc. All rights reserved.
  4. 4. High Risk Monitoring InvestigationCopyright © 2006, SAS Institute Inc. All rights reserved.
  5. 5. Unique Characteristics Financial Intelligence Unit shares Data w/Loss Operations (Fraud) department Unique Text String Scenarios Business Analyst Function 3 million accounts monitored per night 30 Analysts / Investigators Supervised Routing ASP/Hosted EnvironmentCopyright © 2006, SAS Institute Inc. All rights reserved.
  6. 6. Sovereign Best Practices Interactive Risk List Management Advanced Analytic Techniques • Near Neighbor Detection • Link Analysis Scenario Tuning AML Data for Opportunity ManagementCopyright © 2006, SAS Institute Inc. All rights reserved.
  7. 7. BB&T Ninth largest U.S. financial services holding company Total assets $122 billion as of 08/01/07 In the past 16 years, BB&T has acquired • 60 community banks and thrifts • 73 insurance agencies • 25 non-bank entities Primary market segments are comprised of 50% retail and 50% commercialCopyright © 2006, SAS Institute Inc. All rights reserved.
  8. 8. Copyright © 2006, SAS Institute Inc. All rights reserved.
  9. 9. Unique Characteristics Transaction Monitoring team taking over Currency Transaction Reporting processes First Customer to incorporate KYC scores into the monitoring process 10 million accounts monitored per day 10 Lines of business monitored 30 Analysts / InvestigatorsCopyright © 2006, SAS Institute Inc. All rights reserved.
  10. 10. Best Practices Monitor ALL transactions through SAS AML Strong Executive Sponsorship Monitor Commercial accounts monthly Scenario Analysis & Tuning Manage Risk Lists for EDDCopyright © 2006, SAS Institute Inc. All rights reserved.
  11. 11. About Bank of America #1 Retail Bank in North America Have a relationship with 1 in 3 US Households $ 1.5 Trillion in Assets Under Management 65 million customers Retail, Commercial, Private Banking, Global Corporate Investment Bank, TrustCopyright © 2006, SAS Institute Inc. All rights reserved.
  12. 12. Unique Characteristics 30 million daily transactions Monitor over 1 billion transactions per night Investigations generated by • SAS Transaction Monitoring • Surveillance • Investigation • Field Alerts / Manual 45 Analysts / Investigators 25 +/- ScenariosCopyright © 2006, SAS Institute Inc. All rights reserved.
  13. 13. Best Practices Scaling large data volumes in Teradata “Business Intelligence” Layer • Reduction • Triage Team of SAS Business Analysts Hit Rates “In database” monitoringCopyright © 2006, SAS Institute Inc. All rights reserved.
  14. 14. Washington Mutual $ 355 billion in Assets Under Management Regulated by Office of Thrift Supervision Cease & Desist OrderCopyright © 2006, SAS Institute Inc. All rights reserved.
  15. 15. Deficient Processes Failed to file SAR’s & CTR’s in timely manner Controls for SAR decisions CIP / Risk Scoring Measuring Effectiveness of Monitoring Aggregating Cash Transactions Identifying Customer Relationships- NetworksCopyright © 2006, SAS Institute Inc. All rights reserved.
  16. 16. Questions & Answers David Stewart, CAMS Director, Financial Crimes & Compliance SAS Americas SAS Institute Inc. T-4, SAS Campus Drive Cary, North Carolina 27513 United States 919.531.6250 david.stewart@sas.comCopyright © 2006, SAS Institute Inc. All rights reserved.
  17. 17. Copyright © 2006, SAS Institute Inc. All rights reserved.

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