SAM Upgrade & Implementation
A New York Based Broker Dealer experienced poor performance from its SAM transaction monitoring (version 3.7) and was looking to upgrade its system, leveraging the lessons learned from the previous experience and looking to increase the accuracy and efficiency of its AML system. The Organization also required complete data sourcing to the new version, including governance infrastructure and control. Alius (A Matrix-IFS company) was called upon to perform the upgrade, data and alert analysis and provide implementation design that included immediate enhancements to mitigate risk in a manner consistent with regulatory requirements.
Alius provided a comprehensive analysis of existing data processing, transformations, scenarios, and alert productivity in order to enable the most effective monitoring of their AML program using Actimize SAM and CDD.
- Alius reviewed the data from different upstream source systems for validity, accuracy, timeliness and completeness.
- Procedures were developed to handle the identified issues and address missing or inaccurate data.
- Alius evaluated the data transformation of existing ETL and developed a new ETL process to feed into the SAM solution.
- An enhanced monitoring system was designed, given the red flags and risks that were not covered by the existing system and planned a mitigation approach to remediate pending regulatory comments.
- Segmentation analysis and tuning methodology were performed to create risk-based models to understand the scenario coverage vs. risk assessments.
- Alius Determined the strategy for setting thresholds based on scenario design and risk and developed a new scenario testing model to evaluate the transformation logic critical to the client’s AML monitoring environment.
- With the new ETL in place, data flowing into the system was now more valid, accurate, and complete
- The enhanced monitoring system was able to catch red flags and risks that were uncovered previously
- The new risk-based models allow investigators to make more sound decisions
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