Investing in robust and reliable MI to support the TM strategy can often be considered a low priority or even be de-prioritised due to other challenges faced during an automated TM implementation.
To fully realise the benefits of your investment in your TM framework, MI is something that should be given due consideration and a realistic budget.
Understanding how the MI can support your operations and overall TM strategy will help clarify what MI is necessary. Knowing your audience and being clear on their roles and responsibilities will help clarify which MI should be presented to the different strands of management.
An effective TM MI model will provide:
- Deeper understanding and better decisions on rule effectiveness and strategic planning – the MI can indicate how well a rule is performing and support the decision-making regarding implementation of new rules, or the need for rule tuning.
- Stronger governance and oversight by MLRO and senior management – allowing for automatic escalation of issues and trends.
- More effective AML risk management – the MI can highlight underlying patterns of behaviour, these risks can be highlighted to the relevant business areas for follow up, etc.
- More efficient resource planning – timelines for processing and closing alerts can indicate if there are backlogs building up.
- Improved day to day operational effectiveness – particularly important for the AML investigations areas, but also IT and management. For example, alert volumes processed per day, tracking system performance and outages, batch processing times, etc.
- More effective data quality monitoring – sudden spikes or reductions in volumes of alerts could indicate changes in underlying data indicating a potential issue with the data flows.
- Improved ability to satisfy regulatory requirements – regulators have highlighted the need for management oversight and have identified a lack of comprehensive MI analysis regarding alerts as bad practice.
As with any MI, the value will only be realised if both the high-level information and the more detailed statistics are actively reviewed with appropriate follow on actions recorded, tracked, and actioned.
SQA Consulting can provide you with assistance in setting up your TM infrastructure from the implementation of the system, tuning rules right through to setting up the governance structures, processes and procedures, and MI, followed by assurance reviews.
Please contact us to find out more about this article.