An operating model for AML
How the job is done. People, systems in some new processes
AML = KYC + TM
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Updated knowledge of who your customers are and what AML risks they impose as well as ongoing monitoring transactions are the foundations for the analysis and reporting expected of companies under supervision
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The operational model describes the workflow where people and systems work together in defined processes to detect and prevent the company from being used for money laundering.
Processes in interaction
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The central process domains within AML are
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Know Your Customer "KYC", with CDD, EDD and ODD supporting the customer lifecycle from onboarding to offboarding
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Transaction Monitoring of customer transactions to identify deviations from expected behaviours
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Analysis and Reporting
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The operational model for AML interacts with and is part of the company's overall operational model. Both the customer journey and risk control are usually closely integrated
Experiences
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A high degree of automation is desirable. But not everything can or needs to be automated. The nature of the customer portfolio and transaction patterns may set the priorities.
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The interaction between KYC & TM is difficult but central to be able to analyze. The transactions must be analyzed based on knowledge of the parties. While transaction patterns build up and develop a customer profile.