SAS Compliance Solutions 7.1 Fundamentals For Consultants: The Industry

SAS
Compliance Solutions 7.1
Fundamentals for Consultants
The Industry
Fraud & Security Intelligence ‐ Domain Delivery & Enablement
psdfcsenable@wnt.sas.com
C om p a ny C on f id e ntia l – For Inte rn a l U se O n ly

C op yright © S AS In stitu te In c. All rights re se r ve d .
• Hello. Welcome to the Compliance Solutions 7.1 Fundamentals course.
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Page 1 Copy right © SAS Institute Inc. All rights reser ve d.
CONTENTS
(A)ML Compliance Challenges SAS CS
2
C om pa ny C onfide nt ia l – For I nte rna l Us e Only
C opy rig ht © S A S I nst it ute I nc. A ll rig ht s re s e rve d.
• Let’s start with Anti Money Laundering
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What is AML
Money laundering the provision of a legitimate origin to funds obtained by illicit means
Anti Money Laundering the effort by public bodies and FIs to prevent the abuse of the
financial system by criminals for the purpose of money laundering.
Placement Layering Integration

• Money laundering is commonly defined as the provision of a legitimate origin to
funds obtained by illicit means, in particular the so‐called predicate crimes the
proceeds of which fall under anti‐money laundering regulations.
• Anti Money Laundering is the effort by public bodies and financial institutions to
make an effort to prevent the abuse of the financial system by criminals for the
purpose of money laundering.
• Whilst there are many different modus operandi for money laundering, typically the
more traditional money laundering schemes are progressed through 3 phases.
• Placement, where the illicitly obtained proceeds enter the financial system. A typical
measure focusing on this phase is the reporting requirements for cash deposits of
over a threshold amount, typically USD 10,000 or a nearby equivalent in local
currency.
• Layering: also referred to as obfuscation: the activity whereby funds are transferred
across multiple accounts and/or multiple FIs, potentially spread across multiple
countries or jurisdictions, and through different paths, to obfuscate the relation
between these funds, their ultimate beneficial owner(s) and its illicit origin.
• Integration is the last phase and pertains to the further absorption by the financial
system of these funds as legally obtained means and the further use of the funds
through the financial system.
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Exercise 1: Running a Front
You are a successful criminal with too much tainted cash. You also own a store.
How would you get that money safely into your bank Account without raising suspicion

• A typical money laundering scheme is the one using the front store or front business:
• which is either
• real business in which legitimate commercial activity is supplemented with ‘fake’
commercial activity, artificially increasing the ‘profitability’ of your firm
• Not a real business but commercial success is pretended: your dirty money is
supposed as the ‘profit’ of your business.
• This is a very simplistic example …. But you get the idea.
• Trade based money laundering has endless variations on this theme, from empty
shell companies producing fake invoices to more sophisticated schemes whereby
actual bill of ladings, volumes, values or prices of actual goods are artificially
inflated.
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Exercise 2: Integration through loan back
• You have money from crime.
• You own Company 1.
• You also own Company 4. 1 2 3 4
• You know and trust Ms. B
• Ms. B owns Company 2
• Company 2 and Ms. B’s
salary are unofficially funded
by you
• Ms. B owns Company 3
• Companies on the Caymans
do not need to disclose their United States Cayman
shareholders Islands
= Loan
How will you launder your money? = On paper payback (pretend)
• A typical integration mechanism is through a lease or loan back construction
• You as director of Company 1 receives a legit salary from your company 1.
• That company pays the salary from a credit it obtains from a US based company 2,
owned by Miss B (who is paid by Mister A)
• Company 2 lends the money it obtained from a it own loan from Company 3, situated
on the Cayman Islands, where shareholders do not need to be disclosed
• Company 3 has the money from the sale of the building it owned to company 4 (who
buys it with the illicit funds), and its leases back the building to company 3 for which
company 3 is paying a monthly fee. This layered loan construction does not only make
it more difficult to follow the money, it also breaks the connection between you as
the the ultimate recipient and you as the single shareholder of company 4 and
benefactor of company 3 and 2.
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Who launders money?
The usual suspects:
Drug Barons Traffickers Corrupt Officials
Narcotics trafficking Human trafficking Tying in to the notion
being the first and increasingly in the of Politically Exposed
initially only predicate spotlight partially due Persons (PEP)
crime for Money to migration issues
Laundering across the globe
• Money Laundering is performed by the usual suspects …
• … Drug traffickers with Narcotics trafficking being the first and initially only predicate
crime for Money Laundering. The image image depicts Edgar Manual Valencia Ortega,
aka El Chapo, who pleaded guilty to money laundering conspiracy. According to
federal prosecutors, Ortega laundered as much as $3.5 million made from drug sales
in the U.S. to Mexico over a two‐year span)
• ... But also perpetrators of other forms of organised crime and trafficking, such as
Human traffickers and counterfeit cigarette smugglers (image source:
http://www.humanrightsfirst.org (on 18 May 2017)
• PEPs or Politically Exposed Persons is an AML concept resulting from corruption by
state officials. tThe image depicts Bahrain State Minister Mansour Bin Rajab who was
dismissed by the Bahraini king from his post after allegations of involvement in
corruption and related money laundering in 2010
• ...
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Who launders money?
Fraudsters Lawyers Real Estate Tycoons Countries

Fraud and Money Criminal Defence are Real estate commerce Some jurisdictions still
Laundering often is a criminally liable if they and construction lend allow for tight bank
one‐act‐crime know their fees are paid themselves easily for secrecy laws conducive
punishable as separate from the proceeds of money laundering of money laundering
offences crime activity
• ... But money laundering is also committed by …
• ... Fraudsters (the image depicts Madoff, the most notorious ponzi scheme fraudster
who was also indicted with and convicted for money laundering: fraud and money
laundering is often commited in one and the same act.
• ... Lawyers, Attorneys and Sollicitors (The image depicts a Dutch criminal defense
lawyer who also happened to be a TV personality, but later was removed from the bar
following the conviction of money laundering through accepting payments of his fees
by his clients, of which he knew or must have known that these payments were done
purely with the proceeds of crime, the very same acts he represented his client for in
court.)
• … real Estate tycoons – as real estate transactions lend themselves perfectly for
money laundering (the image depicts Joseph Lau Luen Hung a Hong Kong billionaire
who was convicted for money laundering and is now a fugitive. source)
• Country depicted: Switzerland which tops the Financial Secrecy Index
http://www.financialsecrecyindex.com/
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Who launders money?
FIs Students? Elderly…?

But also …
Occasionally banks are Students are ‘Vulnerable persons’
through and through approached by participating in
corrupt or established launderers to easily investment / savings
for the purpose of make an extra buck. schemes can be
aiding ML (Too) gullible? unwitting mules
Questions ‐ How can FI’s identify the money launderers amongst these very different customer types? ... Should they?
What would a transaction monitoring pattern look like? And how should FI’s treat customers who let their accounts
8 being used as mule accounts? ...as criminals or as victims...?
• But also entire Banks can be the perpetrators : Photo: BCCI ‐ At its peak, the Banque
de Credit et Commerce International (BCCI) was the seventh largest private bank in
the world. However, during the mid‐1980s the bank was found to be involved in
various fraudulent activities including laundering of vast amounts of dodgy money.
Billions in criminal profits, including drug money, went through its accounts. The bank
was not too picky about its customers.:Clients included Saddam Hussein, former
military dictator of Panama Manuel Noriega, and Palestinian terrorist leader Abu
Nidal. It has also been alleged that the CIA used accounts at the BCCI to fund the
Afghan Mujahideen during their war with the Soviet Union in the 1980s.
• … but in the pond of money laundering not only big fish swim, but also smaller fry.
Students form a demography targeted by money launderers who approach them for
the use (or better: absue) of there bank accounts as mule accounts to slush funds.
Some of the money will stay behind as payment to the ’mule’). Whilst some of these
students may pose themselves as victims (perhaps of their own gullibility), their banks
nromally view and oust them as complicit.
• .... and elderly are increasingly recognized as vulnerable adults and more prone to be
conned into a money laundering scheme involving their accounts as mule accounts,
for example under the false cover of a lucrative pension scheme. Again, are they the
innocent, somewhat naieve bystanders trying to compensate for economic downturn,
or culpable co‐offenders driven by their greed.
• Questions: how can FI’s identify the money launderers amongst these very different
customer types? ... Should they? What would a transaction monitoring pattern look
like?
• Quaetion: how shoudl FI’s treat customers who let their accounts being used as mule
accounts? ...as criminals or as victims...?
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CONTENTS
9
• Let’s take a closer look at the Compliance domain.
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Compliance
Money Terrorist Tax Bribery Sanctions

Laundering Financing Evasion Corruption Blacklists

• Compliance has become an industry by itself
• Compliance is broad in scope and covers a range of unwanted activity: money
laundering, terrorist financing, tax evasion, bribery and corruption, and other
behaviors such as not adhering to trade embargo’s and sanctions, resulting in entities
being listed on the watch lists or sanctions lists
• It’s Scope is still increasing, meaning Financial Institutions', whilst most of these are
private sector profit driven companies, are increasingly drawn into the public sector
realm of law enforcement and have a legal obligation to support the fight against illicit
behaviors through active transaction monitoring and customer due diligence.
• FI’s cooperate not just to avoid regulatory punishment but also for the intrinsic good
of avoiding accounts and services being abused by criminals for their own purposes …
• .... Thereby contributing to a fairer society
• In this deck we will be focusing on two of the SAS Compliance Services components:
AML Transaction Monitoring and Customer Due Diligence
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Compliance Interactions
Private Sector Public Sector
(Penal) Sanctions
Compliance Review
alerts C Regulator
Fines / Measures (Penal) Sanctions
Investigation
Customer Employee FI Court
Regulatory reports cases indictments

FIU Prosecution
investigation Information Request
11
• Most regulated FI‘s operation in the private sector
• Most have a Compliance Department which manages AML operations and run a
transaction monitoring system
• They monitor transactions of customers and receive alerts on unusual behavior
• In some cases this will lead to an internal investigation
• Alerts and investigations can extend to employees too
• FI‘s and Compliance Operations are supervised by Regulators, aka Regulatory
Watchdogs. These conduct reviews to assess the robustness of the compliance
procedures, especially transaction monitoring, watchlist checking and follow up
• If a regulator is not satisfied with the robustness of systems, models and
operations in place, it can impose hefty fines and other measures.
• If at a bank an internal investigation can‘t take away suspicions, then a regulatory
report will be filed to the applicable Financial Intelligence Unit. Sometimes the FIU
is part of the Regulator, but not in all countries, sometimes it is part of law
enforcement and the FIU is a special financial police unit.
• The FIU can decide to investigate the customer that was reported, but also the
employee involved... and reach out to the FI for additional information
• Ultimately the FIU forwards its cases to the prosecution, who can decide to bring
the case to court. Sanctions may follow a verdict and both verdict and sanction
could imply the FI.
• Many of the larger FIs’s have established internal FIU, to deal with ML and ML
investigation at a central corporate (global) level.
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• In Private Sector FI’s the Money Laundering Reporting Officer (MLRO) is a role
required by statutory law and the MLRO heads up the internal FIU, if any. Often
the MLRO is thier Chief Compliance Officer.
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Page ‹#› Copy right © SAS Institute Inc. All rights reser ve d.
REGULATORY FRAMEWORK
• Statutory Law & Regulations (local per country / jurisdiction)
• Federal Acts (e.g. US) and/or Treaties + Directives (UN, EU)
• FATF 40+9 AML+CTF Recommendations
Examples
• GL UN Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances
• GL UN Convention against Transnational Organized Crime.
• GL FATF 40 Anti‐Money Laundering Directives
• GL FATF 11 Anti‐Terrorist Financing Directives
• GL FATF List of Non‐Cooperative Countries and Territories
• US Bank Secrecy Act (BSA), US Patriot Act
• EU Anti‐Money Laundering Directives ( I, II, II and IV )
• UK Proceeds of Crime Act 2002 , Anti‐Money Laundering Regulations
• NL Wet MOT (Melding Ongebruikelijke Transacties)
12 C om p a ny C on f id e ntia l – For Inte rn a l U se O n ly
• It is important to understand Compliance is not driven primarily by commercial
business considerations
• … but by law and legal frameworks that are binding to FIs
• This slides list a dozen of examples of international regulations
• Globally each country/jurisdiction has its own localized version of the internationally
applicable regulatory framework, , such as in the US the Bank Secrecy act, the
Proceeds of Crime act in the UK, or the Wet Melding Ongebruikelijke Transacties in
the Netherlands.
• There are some international treaties or arrangements that are internationally
binding with force of law
• For example The EU countries have to implement the EU Money Laundering
Directives, but implementation happens locally: each country will adopt its own
legislation to bring the Directive(s) into effect
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CONTENTS
13
• Let’s have a look at the trends in the Compliance domain and the challenges this
poses to the financial institutions.
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Industry Evolution
FROM TO
Rule based Risk based
Regulator decides Financial Instit. decides
Simple logic Complex models
Heuristic Rules Hybrid Analytics
 More False Positives Less False Positives 
 Less False Negatives More False Negatives 
Demonstrating Explaining
to the regulator to the regulator

• The regulatory pressure on FI’s is ever increasing
• The regulatory framework since 2004 adopted a risk based approach to decrease the
astronomous number of (false positive) reports under the rule based approach
• However, under the risk based approach FI have to make much more effort to
• Come up with relevant models
• Explain to regulators the validity of these model
• Regulators become better and better in understanding the analytics behind AML and
FI’s are increasingly reluctant adopting black box models that they cannot explain
themselves in terms of how ML risk is being calculated
• Whilst huge fines can be given by regulators for non Compliance (a financial and
reputational costs FI deseperately want to avoid), the operational cost of compliance
must also be curbed, as directly affecting the bottom line of the FI.
• Better analytics reduce the number of false positives and produces more intelligent
and intelligible alerts, making the follow up process more cost efficient
• SAS is better positioned than any other market player to combine strong analytics
with an open/white box approach and dedicated software to assist the system owner
with independent optmisation of the scenarios and the models underpinning these.
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Regulatory Trends
Regulatory Demand Data 3600 Sophistication Transparency
15 C om pa ny C onfide nt ia l – For I nte rna l Us e Only

• In terms of Regulatory Demand:
• Changing Regulations, with an ever increasing scope: see for example the EU that
has issued its 5th ML Directive
• Increase of areas to be covered (AML TM, Terrorist Financing, Sanction Screening,
Corruption, Tax Avoidance)
• Increasingly complex demand in terms of risk based approach: analytical models
need to be explained in detail
• On Data:
• Increase in the volumes of data to be processed, we have entered the era pf Big
Data.
• Changes in the nature of the data to be assessed
• Increasing look‐back periods exacerbate data volume problems
• There is an increase in demand of real time or on‐demand processing
• A 360 degree view of customers
• Regulators will not allow for compartmentalized view of a multitude of customer
relations across the organization
• All data on one and the same entity must be aggregated assessed holistically
• As a result, Entity Resolution becomes more and more important
• More Sophistication
• from simple rules to analytical models
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• Dynamic velocity analysis
• Outlier detection
• Customer segmentation & peer group analysis
• Profiling
• And lastly Transparency
• Risk based AML systems have become more complex and new capabilities have
also educated regulators
• Regulators have matured in assessing the robustness of the risk based models
• This resulted in increasing appetite with regulators for the details of the AML
approach and methodologies
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The Stakes are High
$ 2.01 Billion $ 1.09 Billion $ 2.05 Billion $ 340 Million
JP Morgan Chase HSBC BNP Paribas Standard Chartered
Sanctions AML AML Sanctions

Violations Deficiencies Deficiencies Violations
US 2011 UK 2012 France 2014 Hong Kong 2012

• To illustrate what is at stake for the financial institutions these are a few examples
where regulators have imposed high fines to Banks across the globe for being
negligent.
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Business Challenges
Emerging Threats Effectiveness Resources Operational Cost

• Emerging Threats
• FI’s need to stay current and be aware of emerging threats and areas of increasing
exposure to ML risks
• Money launderers finding new ways to abuse the system, with increasing
sophistication to circumvent detection
• New products and services offered by the FI such as online payment, mobile
payment, crypto currency services and new investment products, bring new threats
as new offerings are likely to attract money launderers exploiting early‐stage
vulnerabilities.
• Monitoring Effectiveness
• Are your monitoring programs producing the right results? Is there an abundance
of false positives based on transaction monitoring that leads to unproductive use
of precious resource and capacity?
• Resourcing
• There may be Shortage of analytical skilled resources with industry knowledge and
experience.
• The demand for resources to triage alerts and conduct investigations increases as
alerts volumes continue to grow.
• Operational Cost
• Whilst the operational cost associated with investment in anti‐fraud is more likely
to earn itself back due to the direct prevention of losses impacting the bottom line,
this is much less clear for AML.
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• Compliance has become an industry by itself with considerable cost implications
for FI’s. Fines that are given for non‐compliance are significantly and outweigh
operational costs by far, not to speak of reputation damage.
• For every FI it is critical to strike a balance between operational cost and
damage avoided by fraud prevention and AML operations.
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Between Rock and Hardplace
Regulatory Fines Operational Costs
Reduction of false negatives Reduction of false positives
Reputation Damage Customer Dissatisfaction

• The Financial Institutions subject to AML regulations find themselves between rock
and hard place.
• On the one hand they need to reduce false negatives, whereby entities and events
that should have been reported were not.
• As this may lead to regulatory fines, which as we have seen, can be significant
• There is also the risk of reputation damage and the adverse effect on share holder
value
• On the other hand there is the need to reduce false positives
• More false positives lead to an increase in the operation cost for handling the high
volume of alerts, whilst focus and resources are diverted away from the true positives
• Not to mention the customers that are wrongfully alerted on and investigated, or
reported to the FIU (should they ever find out).
• In analytics the trade off is well known: it is easy to reduce the false negatives to a
minimum, but this will come at the cost of much more false positives. Vice versa it is
easy to avoid false positives altogether, but the regulator will not be satisfied if it finds
out that a number of true positives have been missed.
• This were data driven analytical software will truly make a difference, in optimizing
the risk assessment, increase the ratio of productive alerts and also make those alerts
more intelligible and actionable. … and by doing so reduce both false positives and
negatives.
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Business Demands
3600 Whitebox Visualization Delivery Customization Real‐Time

• These trends and challenges become tangible in the customer requirements and
objectives underpinning the RFI’s that we see in the field
• 360o HOLISTIC VIEW OF CUSTOMER
• Integrated functions:
• AML + FRAUD (FRAML)
• AML + CDD
• AML + SANCTION SCREENING + WATCHLIST SCREENING
• CDD + FATCA + CRS
• AML + CUSTOMER SEGMETATION / PEER GROUP ANALYSIS
• AML + ENTITY RESOLUTION / SOCIAL NETWORK ANALYSIS
• WHITEBOX
• Access to all components
• Ability to run the system and make improvements without vendor dependency
• Creating new scenarios, workflows, etc.
• Ability to understand and explain the chosen risk models and settings to regulator
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• DATA VISUALISATION
• Transactional data must be compared against account history over time, to detect
anomalies
• Transactional Data must be view]ed in the context of a peer group
• Data Lineage Reports are important to reconcile input and output, so that no
tranactions are unknowingly omitetd from monitoring
• System Performance Reports need to highlight low performing scenarios that
subsequent;y can be improved or deactivated
• Operational MI Dashboards need to give insight in team and team member
progress and assist managers in balancing workload
• Delivery
• OOTB as much as possible
• Reduced Effort
• Reduced Time
• Reduced Cost
• Reduced Risk
• Understanding what you buy
• Getting what you bought
• CUSTOMISATION
• User access / alert or case flow
• Regulatory Reports, as non US FI’s report to different local regulators with different
reporting definitions
• UI s need to in different languages be for non‐English speaking end users
• But customisation must come without steep increase implementation effort / cost
/ risk
• REAL TIME
• We also see an increasing demand for real time
• At the moment there is no regulatory requirement to perform AML TM inj real
time
• But our customers ask for sanction screening in real time, which is monitoring
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transactions before they are executed to see if any participants are on a sanction
list
• And also on‐demand customer risk scoring is increasingly a must‐have: FI’s want to
risk assess the customer at the very moment of onboarding, before the account is
opened.
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CONTENTS
20
• Let’s see how SAS AML and CDD meet our customers in realizing their regulatory risk
objectives.
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Value of SAS Solutions
Data Analytics Proven Enterprise White Box Real‐Time

• On the part of Data
• ETL tools including DI Studio or Base SAS
• Entity Resolution is supported by Dataflux and the Quality Knowledge Base, both SAS
products in the AML package
• SAS PSD has written jobs to accelerate the set up of the ETL from staging to the ntivee
AML Core database
• Proven, Open, Customizable Compliance Solutions Data Model
• In terms of Analytics
• Understandable, Defendable, White Box Analytics
• Real Time Analytics, Batch Analytics, Network Analytics
• Monitoring Tuning Methodologies
• SAS brings to bear Proven Methodologies
• Proven Implementation Methodologies.
• Single Vendor, Single Contract to meet all there needs.
• Point Solution Offerings
• Integration Services
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• Industry Experts
• SAS provides Enterprise Solutions
• Capability of integrating multiple tools and solutions
• E.g. AML + CDD fully integrated meet Regulatory 360 demand, even more with
Entity Resolution
• SAS is predominantly Whitebox
• Customers have back end access to the database and sas macro’s
• Have full visibility of rules and models that are deployed
• Which allows them to better explain to and satisfy the regulator
• REAL TIME
• SAS R&D is currently working on a real time solution for sanction screening and
customer risk assessment.
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SAS Financial Crimes across the Globe
“18 of the 20 largest
global banks rely on
SAS to mitigate
financial crimes risk”
22
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How SAS AML 7 meets demands
3600 Whitebox Visualization Delivery Customization Real‐Time
Not 7.1
New UI Scenarios
Entity Focus Back end Access Standardized Only
VA AR
23
• Entity Focus
• Th 360 degree holistic customer view requirement is met by a strong focus on the
entity viewed from multiple different angles, which we will cover in detail in the next
slide.
• The Whitebox requirement is met by Front and Back end access
• Front end access to settings in the preferences list
• Front end access to scenario details through scenario Admin
• Back end access to databases and thrugh SAS enterprise guide
• Back end platform access through SAS Management Console
• Back end access to non‐compiled sas code
• And if needed Back end access to REST services
• Data visualization demands are met by the AML 7.1 UI + Visual Analytics
Administration Reporting module
• HTML5 UI provides better end user experience, independent of Flash which will no
longer be supported.bThs includs
• Improved navigation
• Interactive Graphs
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• Network visulualisation
• Funds Tracker Sankey diagram
• 7.1 comes
• Fully configured, ready–to‐go out of the box
• With limited options for customization, only where it truly matters
• This will lead to reduced time to value, at reduced cost and with much less project
risk
• It allows the customer to understanding what they buy
• And then getting what they bought, a reliable versatile AML tm and Customer
scoring solution
• Customization
• 7.1 allows for customization where it matters: scenarios and models
• Additional fields can be added to the details screens
• There is a sample custom regulatory report delivered with the solution as a head
start for localized reporting
• The VA AR reports can also be customized
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Zooming in on Entity Focus
ENTITY HISTORY HISTORIC ACCOUNT SOCIAL CONTEXT
• Alerts role up to entity BEHAVIOUR • Other Accounts for entity
• Alert history in search results • Outlier detection against • Other Account Holders
• Global and Targeted Search history on account • Household members
• Case History Available • Profile Scenarios: • Funds Tracker
• Fuzzy logic Watchlist look up expectation parameters
3600 • N days Transactions history
GEOGRAPHIC CONTEXT CUSTOMER BASE COMPARISON CUSTOMER RELATIONSHIP

• Scenarios for trx’s to/from • AML Score ACROSS ORGANIZATION
high risk countries and tax • Bayesian Scoring • single Tenancy only
havens • Predictability Score • VA needed for multi‐tenancy
• Map visualization • Ability to create customer • Entity Resolution
• VA AR Geo spread segments
visualization
Entity Focus
• How does SAS AML deliver the 360 degree customer view?
• One of the key unique selling points of the SAS AML 7.1 solution is that it allows for a
holistic view of the customer in terms of AML
• … and view the relevant information in a wider context. This context can be:
• Historical: customer/account against his/her/its own history (e.g. profiling scenarios,
look back period, outlier detection)
• Some scenarios leverage geographical elements of the transactions, customers and
accounts
• Customer base comparison: were behavior on the accounts is compared against
thresholds set on the basis of analysis of the entire customer population
• Some scenarios look from a social context or demography perspective: transactions
can be aggregated at household level, customer can be compared against other
customers in same segment or peer group, the funds tracker visualizes recurring or
significant money flows between customers and to or from external parties.
• Entity resolution capabilities, although not out of the box, can help mapping
Customer relations across the organization: this brings us back to holistic view of a
customer.
• note that multi tenancy will separate data and entity related data cannot be rolled up
within the UI across multiple tenants … but VA views can be created that can
overcome these barriers between tenants
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• Note: the history of a customer within the application can be looked at through
the SOLR search, where, for example, also closed alerts will be shown if searching
for a specific customer. And the system can be configured so that historic
dispositiond alerts can be shown in the customer detail screen.In the section on
Additional Details we will show you how.
sas.com
Thank you.
For any questions, comments or
suggestions for this training, please
contact us at psdfcsenable@wnt.sas.com
The following persons contributed to this course:

• Thank you for watching this. If you have any questions, comments or suggestions,
please contact us at psd fcs enable@wnt.sas.com.
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SAS

C om p a ny C on f id e ntia l – For Inte rn a l U se O n ly

(A)ML Compliance Challenges SAS CS

Placement Layering Integration

C om pa ny C onfide nt ia l – For I nte rna l Us e Only

C om pa ny C onfide nt ia l – For I nte rna l Us e Only

Fraudsters Lawyers Real Estate Tycoons Countries

FIs Students? Elderly…?

(A)ML Compliance Challenges SAS CS

Money Terrorist Tax Bribery Sanctions

C om pa ny C onfide nt ia l – For I nte rna l Us e Only

Regulatory reports cases indictments

(A)ML Compliance Challenges SAS CS

C om pa ny C onfide nt ia l – For I nte rna l Us e Only

Regulatory Demand Data 3600 Sophistication Transparency

15 C om pa ny C onfide nt ia l – For I nte rna l Us e Only

$ 2.01 Billion $ 1.09 Billion $ 2.05 Billion $ 340 Million

JP Morgan Chase HSBC BNP Paribas Standard Chartered

Sanctions AML AML Sanctions

US 2011 UK 2012 France 2014 Hong Kong 2012

Emerging Threats Effectiveness Resources Operational Cost

17 C om pa ny C onfide nt ia l – For I nte rna l Us e Only

Reduction of false negatives Reduction of false positives

C om pa ny C onfide nt ia l – For I nte rna l Us e Only

3600 Whitebox Visualization Delivery Customization Real‐Time

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