In a financial world that's increasingly connected and complex, monitoring transactions is not just good business practice — it's a regulatory necessity. Anti-money laundering (AML) transaction monitoring stands as a crucial barrier against financial crimes, which ensures the integrity of financial systems worldwide. For financial institutions, the challenges of AML compliance and the tools to meet them continue to evolve. In this blog post, we'll walk through the basics, best practices, and future of AML transaction monitoring. What is AML transaction monitoring? AML transaction monitoring refers to the systems and processes financial institutions use to detect and report potentially suspicious transactions to the Financial Crimes Enforcement Network (FinCEN) under the United States Department of Treasury, which spearheads the efforts to track financial crimes — money laundering and financing of criminal or terrorist activities. By continuously monitoring customer transactions and establishing patterns of behavior, suspicious activities can be identified for further investigation. The role of AML transaction monitoring AML transaction monitoring identifies potential criminal activities and helps maintain a clean and efficient financial ecosystem. By being proactive in preventing the misuse of services, organizations can protect their reputation, strengthen customer trust, and uphold regulatory requirements. The challenge of false positives However, AML compliance is not without challenges. The systems in place often produce many 'false positives', transactions identified as potentially suspicious that, after investigation, turn out to be mundane. These false alarms can overwhelm compliance departments, leading to inefficiency and potentially missing real red flags. Why is AML transaction monitoring important? Understanding the importance of AML transaction monitoring requires a broader look at the implications of financial crimes. Money laundering often supports other serious crimes such as drug trafficking, fraud, and even terrorism. The ability to interrupt the flow of illicit funds also disrupts these additional criminal networks. Furthermore, for organizations, the cost of non-compliance can be substantial — financially and reputationally. Penalties for inadequate AML controls can be hefty, signaling the need for robust monitoring systems. Specifics on compliance Compliance with AML regulations is not a choice but a must. Financial institutions are required to comply with AML laws and regulations to protect their businesses and the industry as a whole. This includes understanding and adhering to regulation changes, which can be complex and have significant operational impacts. How does AML transaction monitoring work? There are two main approaches to transaction monitoring: Rule-based systems: These rely on pre-defined rules that flag transactions exceeding certain thresholds, originating from high-risk countries, or involving specific types of activities. Scenario-based systems: These use more sophisticated algorithms to analyze transaction patterns and identify anomalies that might not be captured by simple rules. This can include analyzing customer behavior, source of funds, and the purpose of transactions. Most organizations use a combination of both approaches. Transaction monitoring software is a valuable tool, but it's important to remember that it's not a foolproof solution. Human analysis is still essential to investigate flagged transactions and determine if they are truly suspicious. Implementing AML transaction monitoring solutions Implementing a robust AML transaction monitoring system requires the right technology and the right strategy. Beyond the software, it's about embedding a culture of compliance within the organization. Choosing the right AML solution The right AML solution should be based on the specific needs of the institution, the complexity of its operations, and the sophistication of the fraud landscape it faces. It's imperative to pick a solution that is agile, scalable, and integrates seamlessly with existing systems. Leveraging KYC and CIP programs Know your customer (KYC) and customer identification program (CIP) are deeply connected to transaction monitoring. Implementing a robust KYC program helps to establish a strong customer identity, whereas a solid CIP ensures that essential customer information is verified at the time of account opening. Automation and AI in AML compliance Automation and AI are revolutionizing AML compliance, especially in transaction monitoring. AI systems, with their ability to learn and evolve, can significantly reduce false positives, making the compliance process more efficient and effective. Advanced AML solutions and the future Technological advancements are constantly reshaping the AML landscape, including solutions incorporating big data analysis and machine learning. Utilizing big data for better insights: Big data analytics provides an unprecedented ability to spot potential money laundering by analyzing vast amounts of transactional data, allowing for better contextual understanding and the ability to identify patterns of suspicious activity. Machine learning and predictive analytics: Machine learning technologies have the potential to refine transaction monitoring by continuously learning new behaviors and adapting to evolving threats. Predictive analytics can help in identifying potential risks well in advance and taking pre-emptive actions. The human element in AML Despite the advancing technology, the human element remains crucial. AML systems are only as good as the people who operate them. Organizations must invest in: Continuous training and skill development: Continuous training ensures that employees remain updated on regulations, compliance techniques, and the latest tools. Developing a team with AML expertise is an investment in the institution's security and success. Cultivating a compliance culture: Cultivating a corporate culture that values compliance is vital. From the highest levels of management to front-line staff, a mindset that embraces the duty to protect against financial crime is a powerful asset in maintaining an effective AML program. How we can help As a leader in fraud prevention and identity verification, Experian’s AML solutions can help you increase the effectiveness of your AML program to efficiently comply with federal and international AML regulations while safeguarding your organization from financial crime. We provide data, models, and automated systems and processes to monitor, detect, investigate, document and report potential money laundering activities across the entire customer lifecycle. Learn more about Experian’s AML solutions *This article includes content created by an AI language model and is intended to provide general information.
Since 2002, lenders have been aware of the importance of Know Your Customer (KYC) and the associated Customer Identification Program (CIP) requirements. As COVID-19 has changed procedures and priorities for businesses and consumers across the board, it’s more important than ever for institutions to ensure their CIP process includes ongoing monitoring of identity risk. What is CIP? Standard KYC programs include a Customer Identification Program to verify and validate identities along with due diligence to assess the risks associated with each identity. CIP defines the process by which a business collects data to establish a reasonable belief that the identity is valid, and that the individual is eligible to participate in our financial system. While this process works in conjunction with other fraud mitigation tactics, they serve different purposes. A good CIP program emphasizes the customer experience, regulatory compliance, cost control, and smart growth. Fraud mitigation focuses on ensuring that an eligible identity is being presented by its true owner, rather than as part of a scheme to acquire goods and services with intent to default on repayment obligations. Businesses who focus on solely on fraud mitigation rather than complying with KYC and CIP regulations run the risk of potential harm to business reputation, and of course, financial penalties. Fenergo found that as of the end of 2019, global penalties for AML and KYC non-compliance totaled $36 billion. CIP vs. Fraud Mitigation Many financial institutions equate a CIP program with efforts to mitigate fraud. It’s understandable, as both processes include emphasis on the accuracy of an identity as it’s presented by a consumer. It is assumed that only the true owner of the identity would possess the detailed information necessary to meet CIP requirements and therefore would not likely be committing fraud. There was a time—prior to large scale thefts of stored information, personal details shared through social media and other behavior changes that made personal information very public—when this would have been true. Unfortunately, those days have passed and even an amateur criminal with limited experience and resources could find current, accurate identity information for sale online, information good enough to pass the CIP test and be considered a legitimate consumer. The real challenge is that when they go through CIP, many real consumers may inadvertently provide true information that doesn’t meet the verification standard. This is a result of consumer lifestyle changes outpacing the sources of data used to verify the information they’ve provided. It makes sense; in most years roughly 13% of American adults change their address. New homes, job changes and changes in marital status impact a large number of people every day. Adding to the confusion—it’s life’s changes that prompt people to borrow and purchase. The result is that many of the people that are more likely to fail CIP verification are the very people trying to legitimately access financial services. The result is that CIP verification often isn’t a challenge for those intending to commit fraud, but it can be for genuine consumers. The challenges of CIP In a recent internal study, Experian reviewed the ability to pass a standard CIP strategy that assessed the accuracy of the name, current address, date of birth and Social Security number provided by a large sample of consumers. We then compared legitimate consumers to those later confirmed to have been identity thieves impersonating a victim. Consistently, the identity thieves were at least as proficient at passing CIP as their true-consumer counterparts. In a second step, we applied a fraud score that looked for identity theft by assessing the past uses of the identities, their consistency, velocity and many other characteristics unrelated to the accuracy of the data. The difference between CIP verification and a fraud risk assessment was striking. Across the entire range of fraud risk, the percentage of records that passed CIP verification remained the same. That said, CIP still plays a very important role in risk mitigation. In fact, CIP and fraud prevention are inextricable in financial services. Just as a CIP verified identity can still be fraud, a record that may appear to be low fraud risk may not pass CIP. Since both processes have existed side by side for nearly two decades, each presumes that the other is in place and both are necessary to detect and prevent fraud. Striking a balance CIP verification and fraud mitigation strategies are both necessary and important to protecting assets and the broader financial system from fraud. It’s important to leverage a layered approach where both eligibility and risk are assessed, and next steps for verification include resolution of identity discrepancies alongside verification that ensures an identity is not being misused for fraud. Experian can help you confidently verify customer identities, understand and anticipate customer activities, and implement ongoing monitoring. If you’d like to set up a review of your current strategy or learn more about how we can help you with CIP and fraud mitigation to strengthen your ability to know your customer compliantly, let us know. Contact us
Customer Identification Program (CIP) solution through CrossCore® Every day, I work closely with clients to reduce the negative side effects of fraud prevention. I hear the need for lower false-positive rates; maximum fraud detection in populations; and simple, streamlined verification processes. Lately, more conversations have turned toward ID verification needs for Customer Information Program (CIP) administration. As it turns out, barriers to growth, high customer friction and high costs dominate the CIP landscape. While the marketplace struggles to manage the impact of fraud prevention, CIP routinely disrupts more than 10 percent of new customer acquisitions. Internally at Experian, we talk about this as the biggest ID problem our customers aren’t solving. Think about this: The fight for business in the CIP space quickly turned to price, and price was defined by unit cost. But what’s the real cost? One of the dominant CIP solutions uses a series of hyperlinks to connect identity data. Every click is a new charge. Their website invites users to dig into the data — manually. Users keep digging, and they keep paying. And the challenges don’t stop there. Consider the data sources used for these solutions. The winners of the price fight built CIP solutions around credit bureau header data. What does that do for growth? If the identity wasn’t sufficiently verified when a credit report was pulled, does it make sense to go back to the same data source? Keep digging. Cha-ching, cha-ching. Right about now, you might be feeling like there’s some sleight of hand going on. The true cost of CIP administration is much more than a single unit price. It’s many units, manual effort, recycled data and frustrated customers — and it impacts far more clients than fraud prevention. CIP needs have moved far beyond the demand for a low-cost solution. We’re thrilled to be leading the move toward more robust data and decision capabilities to CIP through CrossCore®. With its open architecture and flexible decision structure, our CrossCore platform enables access to a diverse and robust set of data sources to meet these needs. CrossCore unites Experian data, client data and a growing list of available partner data to deliver an intelligent and cost-conscious approach to managing fraud and identity challenges. The next step will unify CIP administration, fraud analytics and a range of verification treatment options together on the CrossCore platform as well. Spoiler alert. We’ve already taken that step.
Managing your customer accounts at the identity level is ambitious and necessary, but possible Identity-related fraud exposure and losses continue to grow. The underlying schemes have elevated in complexity. Because it’s more difficult to perpetrate “card present” fraud in the post–chip-and-signature rollout here in the United States, bad guys are more motivated and getting better at identity theft and synthetic identity attacks. Their organized nefarious response takes the form of alternate attack vectors and methodologies — which means you need to stamp out any detected exposure point in your fraud prevention strategies as soon as it’s detected. Experian’s recently published 2018 Global Fraud and Identity Report suggests two-thirds, or 7 out of every ten, consumers want to see visible security protocols when they transact. But an ever-growing percentage of them, fueled in no small part by those tech-savvy millennials, expect to be recognized with little or no friction. In fact, 42 percent of the surveyed consumers who stated they would do more transactions online if there weren’t so many security hurdles to overcome were — you guessed it — millennials. So how do you implement identity and account management procedures that are effective and, in some cases, even obvious while being passive enough to not add friction to the user experience? In other words, from the consumer’s perspective, “Let me know you know me and are protecting me but not making it too difficult for me when I want to access or manage my account.” Let’s get one thing out of the way first. This isn’t a one-time project or effort. It is, however, a commitment to the continued informing of your account management strategies with updated identity intelligence. You need to make better decisions on when to let a low-risk account transaction (monetary or nonmonetary) pass and when to double down a bit and step up authentication or risk assessment checks. I’d suggest this is most easily accomplished through a single, real-time access point to myriad services that should, at the very least, include: Identity verification and reverification checks for ongoing reaffirmation of your customer identity data quality and accuracy. Know Your Customer program requirements, anyone? Targeted identity risk scores and underlying attributes designed to isolate identity theft, first-party fraud and synthetic identity. Fraud risk comes in many flavors. So must your analytics. Device intelligence and risk assessment. A customer identity is no longer just their name, address, Social Security number and date of birth. It’s their phone number, email address and the various devices they use to access your services as well. Knowing how that combination of elements presents itself over time is critical. Layered passive or more active authentication options such as document verification, biometrics, behavioral metrics, knowledge-based verification and alternative data sources. Ongoing identity monitoring and proactive alerting and segmentation of customers whose identity risk has shifted to the point of required treatment. Orchestration, workflow and decisioning capabilities that allow your team to make sense of the many innovative options available in customer recognition and risk assessment — without a “throw the kitchen sink at this problem” approach that will undoubtedly be way too costly in dollars spent and good customers annoyed. Fraud attacks are dynamic. Your customers’ perceptions and expectations will continue to evolve. The markets you address and the services you provide will vary in risk and reward. An innovative marketplace of identity management services can overwhelm. Make sure your strategic identity management partner has good answers to all of this and enables you to future-proof your investments.
Legitimate address discrepancies are common, which surprises most people. And handling every address discrepancy as a high fraud risk is operationally expensive and inhibits the customer experience. You can avoid this type of fraud by employing these best practices: Use a distinct Know Your Customer and underlying Customer Identification Program process. Avoid verifications based on self-reported data. Maintain hotlist addresses. Fraud always will find the path of least resistance, and organized criminals will test you daily to isolate the weakest link. Be sure to regularly revisit your own policies and procedures for handling this type of fraud. Address manipulation fraud