AIM accelerator introduction
Financial crime is rising at an unprecedented rate, and financial institutions are continuing to try to fight back. Suspicious activity must be investigated and reported to the relevant authorities in specific formats within tight deadlines. Failure to do so can lead to escalating fines, damage to brand reputation, or even closure of businesses and institutions.
With multiple systems that generate various alerts related to financial crimes, the appropriate staff must handle alerts by using differing processes and timelines. The required data is distributed across multiple systems of record (SOR), commonly without any unified customer view.
Efficient management of all this complexity can prove an almost impossible challenge and result in delays and high costs.
Built upon Pega Foundation for Financial Services™, the Alert and Investigation Management (AIM) accelerator can help financial institutions through the following features:
- A single system to streamline the management of complex alerts and corresponding investigations.
- A 360-degree Customer Master Profile and the ability to consolidate data from multiple SORs into one view.
- Automatically routes the work to the right teams based on complexity, skills, and urgency.
- Automatically enriches and displays key investigations without losing context.
- Reduced manual work and prevention of late submissions of suspicious activity to regulators and law enforcement by using managed Service-Level Agreements (SLAs) and escalations.
Architecture of the solution
The following diagram provides a high-level overview of the solution. In AIM, alert-producing systems, such as Transaction Monitoring, initiate the Alerts. The Event-Driven Architecture receives the Alerts before handing off the Alert for processing through two key Case Types.
The following list outlines the terms and functional areas that comprise the AIM accelerator:
- Alert: An Alert is a set of data generated by an Alerting system, such as Transaction Monitoring or Sanctions Screening. Alerts should contain sufficient information, directly or via reference IDs, to allow another system to process the Alert and take the appropriate business-driven actions.
- Alert reception (Event-Driven Architecture): The reception of Alerts is critical for AIM, which needs to manage Alerts coming from different systems and modules to ensure continuous regulatory compliance. For this purpose, AIM includes an infrastructural component, EDA, that facilitates the implementation of event-driven processes. The EDA component manages the reception of Alerts and events from different sources and routes them to the appropriate applications and processes in charge of their resolution.
- Alert Intake: The core function of the Alert Intake Case is to ingest each Alert that is received, ensure sufficient data and instructions are available to progress the processing of the Alert, and, where necessary, assign it to an Investigation Case. The system automatically creates an Alert Intake Case for each Alert.
- Investigation: The core function of the Investigation Case is to provide a robust and efficient process whereby at least one Alert can be triaged and investigated and, on conclusion of the investigation, run potential Post-Investigation actions such as filing a Suspicious Activity Report to the necessary regulator.
- Investigation Task: The core function of the Investigation Task Case is to collect information and record activities that are external to the system and related to a specific task. For example, information about the Source of Funds related to a transaction. This is facilitated using a questionnaire linked to each task. Specific questions from each questionnaire can be applied based on input driver data.
- Data Link Analysis: The Data Link Analysis (DLA) component maintains a network of key data related to Alerts and Investigations to support the investigation: Transactions, Accounts, and Subjects. The ability to visualize this network of data and relationships and apply filters accordingly helps investigators see the connections they need to complete their work.
- Subject: A Subject is an individual or organization that is included in an Investigation. The relationship that the financial institution has with a Subject impacts the amount of data that is initially available. Subjects are categorized as follows: active customer; known related party of a customer (such as a beneficial owner of an existing customer), or external party unknown to the financial institution. During the Alert Intake process, Subjects are extracted directly from the available data in the Alert. During the automated Enrichment Step in this Process the system can also automatically add additional Subjects to the Investigation as discovered. For example. A joint account holder of the Account included in an Alert.
Demonstration of AIM
The following videos demonstrate how:
- A series of three Alerts from a Transaction Monitoring System are processed and merged into a single Investigation,
- A member of the Level 1 team triages the initial Alert, and escalates to the Level 2 team.
- A Level 2 team member takes the Investigation and performs generated Tasks to ensure that the correct investigation procedures are followed.
- Two further Alerts are automatically merged in the Case and handled.
- Upon finalization of the Investigation activity, an example Suspicious Activity Report (SAR) file is automatically generated for submission to the local regulator.
Alert triaging and Initial investigation
Transcript
Managing the processing of suspicious activity alerts at a financial institution can feel like an almost impossible challenge. Alerts, generated from multiple systems, must all be handled by the appropriate staff, in the correct way, and managed to strict SLAs. The complexity involved, combined with extensive manual work, results in delays and rising costs. Failure to investigate these activities and report to regulators in a timely manner generates fines, risks damage to brand reputation, or can even force an exit from a jurisdiction or removal of product offerings.
The data required to complete investigations will be stored across multiple systems of record commonly without any unified view of the customers involved. An inability to understand the key data relationships involved greatly hampers efficiency and risks inaccuracy for any conclusions drawn.
What if there was a way to streamline the highly complex world of financial crimes investigations by automating more work through artificial intelligence, visualizing important relationships across data, and decreasing the time to file suspicious activity reports, all of this while ensuring your investigators are compliant with your investigation protocols?
Only Pega's Alert and Investigation Management can enable financial institutions to achieve this goal. This demo will show you how.
The Financial Crimes Investigation team at UPlus Bank is using Pega's Alert and Investigation Management solution to delve deeper into a set of Alerts and determine whether their products and systems are being used to carry out criminal money laundering activities. UPlus Bank's transaction monitoring system has triggered an alert. Vanessa Yu, a Level 1 Investigator, will triage the new Alert, determining that further Investigation is warranted and escalate to the Level 2 team. Level 2 Investigator Carl Rios will carry out the necessary Investigation work during which two new Alerts are triggered and automatically linked to the existing Investigation Case. The overall investigations department needs to uncover the truth behind these transactions and ensure that all regulatory requirements are being met.
UPlus Bank's transaction monitoring system has generated an Alert based on three cash transactions to one of its clients. An automated Alert Intake process has enriched the data from the Alert, indexed key relationships, and in this situation, assigned the Alert to a new Investigation Case. Work was automatically and intelligently routed to the correct team based on factors such as urgency, skills, and complexity. Level 1 investigator Vanessa Yu clicks . The highest priority Task from the Level 1 work queue is assigned to her worklist, and the associated Case automatically opened.
All the information Vanessa needs to triage the Alert is readily available via the Preview panel. This ensures that she can view all the data she needs without losing the context of this current task. After viewing the content of the Preview tabs, she opens the Data network analysis tab of the parent Investigation Case.
Visualization of investigation data is critical in allowing Vanessa to clearly see the connections between all key information and more quickly draw reliable conclusions. She can clearly see that the three transactions were just under the reportable threshold of 10,000 dollars and were received from multiple people on the same day.
Using this information, Vanessa determines that potential payment structuring activity is occurring. This must be investigated further, so Vanessa selects the appropriate fields and escalates the Case to the Level 2 team.
You have reached the end of the video.
Investigation tasks and general assessment
Transcript
Level 2 Investigator Carl Rios opens the escalated Case to continue the investigation work. He must carry out detailed research, conclude the investigation, and set which post investigation activities must be triggered. Fortunately for Carl, there is easy access to the full customer profiles that UPlus Bank created during the original onboarding, and keeps updated through an ongoing review process.
Using Pega Live data, he can view information including, but not limited to, Risk Profile, Regulatory Details, Related Parties, and Related Alerts and Investigations. Selecting the Subject Investigations tab, Carl opens the Subject Investigation Case for Dawn Summers. Pulling from a registry of potential Investigation Tasks, Alert and Investigation Management has automatically generated a separate set of Tasks for each of the four Subjects linked to the Investigation.
Each of these Tasks contain a questionnaire to ensure that the correct investigation procedures are carried out, including the collection of additional information that may be used in the submission of a suspicious activity report. Configurable business logic allows a financial institution to drive higher efficiency and stick to procedures by ensuring that only the necessary Investigation Tasks and Questions are generated for each subject.
For example, certain Tasks and Questions may only be applicable to a subject that is high risk. There are five Tasks related to Dawn Summers that must be completed. Clicking for the General Assessment Assignment presents a set of questions. Reading the first question, Carl previews Dawn Summers subject profile and provides an answer.
As the remaining questions are answered, the questionnaire dynamically adapts the required questions in real time based on the responses provided. When all questions are answered, Carl clicks to complete the General Assessment Task. Answers can be pre filled with data where it is already available elsewhere, but for this demo, we fast forward to where Carl has completed all remaining Tasks for the four subjects.
You have reached the end of the video.
New alerts merge
Transcript
Just before Carl is about to finalize the Investigation, two new Alerts are triggered from the transaction monitoring system. Using the same data link analysis technology component that drives the visualizer Vanessa was using, these two new Alerts are merged into Carl's in flight Case and Carl is sent a notification.
Seeing the notification, Carl refreshes the Investigation Case. The two new Alerts show in the Alert list, and the counts in the left hand panels update accordingly. Checking the Subject Investigations tab, he sees there are now three new Cases for Berry Inc., Power Rock Inc., and First Dutch Investments LLC.
The Cases for Earl Jackson and Klaus Duval remain closed, but those for William Hang and Dawn Summers have been reopened. After enriching data from the newly merged Alerts, the system has assessed and updated the remaining work required for the overall Investigation. A full set of Investigation Tasks must now be carried out for the newly added subjects.
For any prior subjects that are not connected to the new Alerts, the Investigation Tasks are safe to remain resolved. However, if prior subjects are connected to the new Alerts, then the associated Tasks must be reviewed. New Tasks may be created, questionnaires may be updated, and existing questions may need to be answered differently based on updated data.
Opening the Subject Investigation Case for Dawn Summers, Carl sees that there are now a total of six Tasks to be carried out, instead of the five presented for the original Alert. The additional Task of review transaction history was applied as the overall Investigation Case moved to a complexity of 'High.'
Loading the first Dutch Investments profile, Karl reviews the related parties, noting the name Earl Jackson was involved in the first Alert.
Once again, the visualizer proves invaluable for making connections. By adjusting the filters, Karl can see the flow of funds between accounts or subjects. Clicking on any of the in the diagram displays additional, relevant information. Karl determines that cash has flowed to Dawn Summer's account, and then joint account holder William Hang has sent those funds via two intermediary entities to First Dutch Investments LLC.
With Earl Jackson depositing some of the original funds and also being a controlling part of First Dutch Investments LLC, he concludes that a report must be filed with the local regulator. With all Alerts confirmed and Investigation Task completed, he selects Finalize investigation and proceeds by clicking .
You have reached the end of the video.
Investigation finalization and suspicious activity report
Transcript
In the Step, Karl must complete the form, building out a narrative of his investigation findings. Karl's conclusion is that this is a reportable suspicious activity. The three Alerts indicate the conclusion rationales of Structuring and Money laundering. And for the actions, he wants a Suspicious activity report to be triggered, as well as a Customer review to be carried out.
Manually preparing investigation narratives from scratch can be difficult, error prone and very time consuming. This is where Pega GenAI™ comes to the rescue to greatly reduce that effort. Using the core Case data, Pega AIM intelligently engineers a prompt, masks any sensitive data, and passes this to Pega GenAI to produce a draft narrative. With the two formats available, Carl picks the more detailed and prescriptive report format. The summary format allows Pega GenAI to be more creative with its output. Carl reviews the draft report carefully and edits it as necessary.
In this demo, Carl proceeds through the Review finalized investigation screen that allows for a review cycle with another colleague. The core investigation concludes, and the chosen post investigation actions are automatically triggered. Finally, switching to Money Laundering Reporting Officer, Hubert Jones, he can see that the Suspicious Activity Report process is well underway for this Investigation.
Combining all the necessary data from the Investigation and the finalized narrative, a file has been automatically created that can be filed with a local regulator. In this example, it is the GoAML format from the United Nations Office of Drugs and Crime. This is actively used by 65 countries worldwide.
In summary, what did we see? Multiple Alerts were enriched, indexed, and merged into a single Investigation for streamlined processing. The investigators used a relationship visualizer, curated previews, and full screens to access the information they needed to complete their work. All in a modern user experience.
Dynamically driven sets of Investigation Tasks and Questions for each subject in the Investigation optimize investigator work, while ensuring adherence to financial institution standards. Pega GenAI created a draft investigation narrative to reduce the time spent during the final steps of the Investigation.
Lastly, finalization of Investigation showed how multiple actions could be triggered including the preparation of a Suspicious Activity Report. Only Pega can streamline the highly complex world of financial crimes investigations by reducing manual work and decreasing the time to file suspicious activity reports.
This reduces the chances of regulatory fines all while protecting against the inevitable damage to your brand and financial crimes are committed using your institution.
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