Andrew Davies from ComplyAdvantage explores how firms can adopt a ‘progressive renovation’ approach to upgrading their screening tools - with targeted investment in the tools and data that will truly impact the quality of their risk intelligence.
A quick scan of recent money laundering news shows financial crime trends impacting individuals and organisations all around the world. Beyond individual corruption in politics and organised crime, major financial institutions have repeatedly been implicated in money laundering cases. At the same time, criminals have impersonated official supervisory bodies like the Financial Action Task Force. In our 2023 State of Financial Crime report, my colleagues and I saw that 58 percent of firms globally planned to increase their compliance staff to cope with growing financial crime risk and complexity.
Yet talent alone can only do so much without the right data and tools. From a lack of integration in the compliance tech stack to unsatisfactory sanctions and PEP data, our most recent survey showed us that firms’ payment screening solutions are struggling to keep up. Indeed, many of the firms I talk to grapple with their legacy systems, finding them difficult to configure in line with their risk-based approach, and therefore unable to keep up with rapidly emerging risks. In this scenario, talent investment is often used to compensate for ineffective, underpowered solutions.
This approach is not sustainable, yet an outright compliance framework overhaul is unrealistic for many firms. So, what’s the best way to support payment screening teams with the right technological investments?
When advising firms, I often suggest an approach that I call ‘progressive renovation’. This provides a cost-effective, productive alternative to more time-consuming, large-scale global technology implementations. Instead, a firm can gradually upgrade its technology alongside balanced human capital investments, leading to more effective risk management over time.
With this approach, the key is to identify the aggregation points within an existing framework most likely to impact efficiency and effectiveness.
For example, a firm might be dealing with multiple cases and alert management systems, leading to backlogs, information siloes, and analyst overwhelm. Rather than overhauling these systems, the firm could consolidate them into an integrated view using an overlay solution. This would help improve the existing framework’s efficiency without requiring a total replacement. After all, a more integrated tool would invariably make it easier and quicker for analysts to make informed decisions, providing all the information they need to do so in one single view.
Other firms may choose to focus on improving sanctions and PEP data, ensuring their teams are equipped with the most up-to-date information when making decisions. For sanctions, how quickly does a current solution reflect regulatory changes – in minutes, hours, or days? For PEP data, is it responsive to a firm’s unique risks, allowing flexible views of relatives and close associates (RCAs) and mid-level or junior political officials?
Some firms may decide to overhaul their payment screening solution. This is still compatible with a broader progressive renovation approach – replacing individual solutions within a larger compliance function can improve the whole system gradually over time. For example, a new screening tool that integrates more smoothly with the existing tech stack helps break down data siloes that could be hobbling other teams’ investigation or detection of suspicious activity.
Despite it often feeling like a mammoth challenge, faster and more effective screening processes can be achieved with targeted investment in the technology and data that will truly make a difference – arming teams with the tools and risk intelligence they need to act swiftly when faced with an alert. Change does not need to be wholesale; by making incremental improvements to safeguard their operations, businesses can take proactive steps toward keeping criminal cash out of the global financial system without complete overhauls.
For more insights from our global survey and practical tips from our Regulatory Affairs team, download The Role of Technology and Talent in Transaction Screening.
About Andrew Davies
Andrew Davies is a financial crime risk management industry veteran and the Global Head of Regulatory Affairs at ComplyAdvantage. Based in New York, Andrew applies his decades of experience to support our products' development, help navigate customer challenges, and offer his strategic guidance to the wider compliance and financial services industry.
About ComplyAdvantage
ComplyAdvantage is the financial industry’s leading source of AI-driven financial crime risk data and fraud detection technology. ComplyAdvantage’s mission is to neutralise the risk of money laundering, terrorist financing, corruption, and other financial crimes. Enterprises in over 75 countries rely on ComplyAdvantage to understand the risk of who they’re doing business with through the world’s only global, real-time database of people and companies. Learn more at complyadvantage.com.
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