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Anti Money Laundering, Data Collection and Reporting. Information Technology Service External Systems Unit Global Programme against Money Laundering . Money Laundering/Terrorist Financing – The World’s Response.

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Anti Money Laundering,Data Collection and Reporting

  • Information Technology Service External Systems Unit

  • Global Programme against Money Laundering


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Money Laundering/Terrorist Financing – The World’s Response

  • Establish a global environment hostile to money laundering and terrorist financing

  • Implement international standards including the FATF 40+9 recommendations

  • Establish Financial Intelligence Units around the world

  • Establish protocols and platforms for sharing intelligence and evidence

  • Secure technical assistance for countries to implement international standards

  • Uniform and standard AML platform - desirable


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Anti-Money Laundering Process

Three essential components of an AML/CFT regime:

A functional compliance culture

Functional regulatory bodies – central Bank, SEC, Insurance Regulator etc

An effective financial intelligence unit tasked with:

The above processes ideally should be automated particularly if they involve high data volumes



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Brief History – ITS

2005 – UNODC appointed project manager for EC project in Nigeria

Significant component – provision of IT solutions to EFCC including NFIU

March 2006 UNODC ITS tasked with developing IT solutions

April 2006 – ITS commences developing database and analytical tools for NFIU

June 2006 – XML Schema introduced to Nigerian reporting institutions

October 2006 – CTR database and basic analytical functions installed in NFIU and tested


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Brief History – GPML

Frequent requests from developing FIUs for IT solutions

Early involvement in Nigeria project including in advisory role to IT component

Potential for goAML beyond the Nigeria project recognized

Simultaneous – work commences on widening the scope of the system beyond Nigeria


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Current – Future

February 07

Data collection tools completed

Analytical functionality available

Drawing tools phase 1 nearing completion

Rules engine under construction

Profiling tool under construction

July 07

STR system completed

Profiling tool completed

Intelligence file management completed

Workflow system completed

Drawing tools phase 1 completed


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Current – Future

September 2007

  • Phase 1 goCASE complete

    June 2008

  • Drawing tools completed

  • Rule engine and editor completed

  • Full user documentation in multiple languages (English, French, Spanish, Russian)

  • goAML (complete suite) VERSION 1.0 READY!

    July 2008

  • Phase 2 goCASE complete


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Designed as a modular system to fit the needs of any FIU irrespective of size

from a single computer with a few thousand processes - up to 500 million processes over 5 year period irrespective of file size

Processes and analyzes reports on:

- Suspicious transactions

- Financial transactions – of any type

- List or alert based reports – CFT etc

Fully electronic data collection and dissemination from any source such tax, law enforcement records, immigration service (passenger movement records), property registrar, vehicle registrar etc….

goAML – global Operations Anti-Money Laundering


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goAML – global Operations irrespective of sizeAnti-Money Laundering

Anti-Money Laundering Solution Building Blocks


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goAML – Collecting and irrespective of sizeManaging Information

Reporting standard defined:

XML based (world standard format)

Samples available for FI IT Personnel

Exhaustive documentation available

Validation application:

Checks for valid XML

All required fields are present

Data types are correct

Ensures reporting entities report in the correct format from day 1


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goAML – Gathering and irrespective of sizeManaging Information

Secure website (SSL 512 bit encryption) for:

Creating reporting entities

- by the FIU

Creating contacts

Changing contact details

- by the reporting entity

Report upload

Report data entry

- manually if necessary

Report verification

- clean up by system


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goAML – Gathering and irrespective of sizeManaging Information

  • Report History

    - what reported

    - accepted/rejected ref number

  • View uploaded report

    - Individually

  • Submission status

    - accepted/rejected

  • Common content for any reporting entity

    - flexible

    - secure information from FIU

    - compliance circulars

    - alerts

    - name lists


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goAML – High Volume Analysis irrespective of size

Support analytical and investigation teams with highly sophisticated reporting capabilities.

Visualize large volumes of data to help understand the big picture.

Monitor potentially suspicious accounts.

Reveal patterns and hidden connections.

Create analytical charts manually or automatically.


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Workflow for STR analysis irrespective of size

Tasks and the process diagram are defined by the FIU users

- can change to suit their own needs

- full visual designer

Task assignment and tracking

- within FIU

- push or pull reports by e-mail

Integrated reporting

- workflow reports

- assignments

- progress

- results

goAML – Collecting, Managing and Analyzing Information


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Integrated source tracking irrespective of size

- tracks externally sourced information

- creates bring-ups, reminders etc

Automatic resource scheduling

- automatically assigns tasks

- monitors workloads

- measures outputs/performance

Case feedback integration

- Produces standardized feedback

- reports as word documents

goAML – Collecting, Managing and Analyzing Information


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Customizable data gathering templates irrespective of size

- standardized format for receipt of information

from outside agencies that decides

transmission medium (email/fax/post)

Time in flight analysis

- Time management measure

goAML – Collecting, Managing and Analyzing Information


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Common user interface across analysis screens irrespective of size

- screens look and feel the same

- supports multiple languages

Workspace based (keep information through different reporting sessions)

- two work spaces available at any one time

- previous work automatically saved

- supports text, tables, merged tables, pictures

goAML – Analysis and Targeting Solution


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Analyst can retrieve, filter and irrespective of sizere-arrange the data accordingly to his/her needs.

- Rearrange data fields

- Change grouping

- Filter data

- Change data sorting

- Save layout

- Export

goAML – Analysis and Targeting Solution


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Linking to other screens from current screen irrespective of size

Allows easy comparison of different accounts, persons or entities

Each window acts independent of others

Copy fields or rows

Makes analysis easy

Very easy to learn

All these components have restricted access

goAML – Analysis and Targeting Solution


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goAML – Analysis Trails Link charts irrespective of sizeassociation charts – transaction flow charts etc

Money and person trails for inbound and outbound transactions

Trail for duplicated addresses, phone numbers and other identification data

Displays:

- source and destination

displayed as nodes

- direction and amount

displayed as arrows


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goAML – Analysis - Pivots irrespective of size

Reports offer many different views of data under analysis

Allows for dynamic user filtering and grouping of related data

Allows for searching for TOP targets - 5/10/50 etc

Flexible data search capability

Simple integration with Excel

- excellent for net worth analysis

- ease of attachment to intel reports

- arrives live so can be manipulated

by receiver


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goAML – Analysis - Intersect irrespective of size

Combines data from two different reports

- User chooses the two reports populated with data and the columns to intersect

Result is displayed in a completely

new window with the intersected data


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goAML – Information Dissemination irrespective of size

Suspicious activity detected

Open a new case – analysis output attached

goCASE picks this up

Export case to MS-WinWord

- Case file remains with FIU

- Output in the form of Intel report

- Sanitised to the level required by the user


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goAML - User and role based functions irrespective of size

Management: Is able to check the submissions and the status of reporting entities. - performance measure/compliance

Analyst: Responsible of conducting the analysis, finding suspicious activities and linking to similar-patterned cases where they exist - analysis

Administrator: Allowed to add new user, give/revoke access to screens and different actions.

Access to certain actions is dependant on the user’s role!


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goAML - Security irrespective of size

Username and password required to access applications.

Access can be granted and revoked per:

- User

- Screen

- Certain actions like copy, export etc.

Access to screens and data is logged.

Data partially encrypted in the database.

- Encryption level and extent at the discretion of the user


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goAML - Security irrespective of size

Access to the system generally or to any part of it at the discretion of the user – the user must “open the gate”

UNODC does not hold private key – cannot decipher encrypted data

Rule engine secure

Database and system tools installed on the user’s premises, UNODC has no independent access


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goAML – System Requirements irrespective of size

• Assumes average data load – 500,000 reports per month

Assumes 15 users

Assumes reasonable level of existing infrastructure including security

- Mail servers

- Local area network

- DMZ with 2 firewalls

- Anti-spam and anti-virus policy

Provide fully redundant environment

- 2 DB Servers

- 2 Application servers

- Storage area network (SAN)

- Backup robot servers

- Public key infrastructure certificates (PKI)

- 15 high end personal computers (PCs)Approx: $220,000


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goAML – Estimated Costs irrespective of size

goAML software package is free of charge

Installation – initial training US$ 80,000

(depending on location – 3 visits x 2 persons)

Annual user license agreement US$ 100,000

- This fee will decrease as more

users take up the system

- Provides support within working

hours in local time zones

- Provides ongoing system development

- Guarantees one on-site visit per year ____________

US$ 180,000


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Breakdown of Costs irrespective of size(Basic installation)

  • Installation – US$80,000

    • Establishment of standard reporting scheme for reporting institutions

    • Training of reporting institution compliance and IT staff;

    • Customisation of report formats and forms

    • Customisation of goAML interfaces to individual user requirements

    • Migration of existing data to goAML database

    • Installation of goAML and completion of data migration

    • Implementation of reporting system

    • Training of FIU management, analysts and IT personnel

    • Follow up and troubleshooting

      Time frame 3 – 6 months depending on existing infrastructure and current operating environment.


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Breakdown of Costs irrespective of size(Basic installation)

Maintenance, support and development fee – US$100,000 per annum

  • Time zone specific, business hour support by e-mail, phone or fax – provided by regional support centers

  • Outside business hours support provided from other time zones where language permits

  • Ongoing, needs based, customization and development.

  • At least one site visit per annum timed to the requirements of the user

  • Continuous minor upgrade and patch service

  • Periodical major upgrades – new releases

  • Regular regional user group meetings and online forums

  • Access, where necessary, to the full resources of the ITS Service of UNODC


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Breakdown of Costs irrespective of size(Standard installation)

Initial Deployment/Installation – US$600,000, maintenance and development fee – US$300,000 pa. (Assumes maximum 15 users)

  • Includes all services of Basic Installation plus:

  • Site assessment

  • Skills assessment

  • Design and supervise build of physical infrastructure

  • Design and plan full system architecture

  • Purchase, delivery and installation of all server and storage equipment

  • Purchase software licenses


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Breakdown of Costs irrespective of size(Premium installation)

Initial Deployment/Installation – US$3,200,000, maintenance and development fee – US$1,200,000 pa. (Assumes maximum 100 users)

  • Includes all services of Standard Installation plus:

  • Purchase, delivery and installation of all equipment (full IT infrastructure and telecommunications)

  • A support team on-site backed up by a development team offsite

  • Purchase software licenses

  • Management of maintenance contracts with suppliers

  • Management of the buildup of the local IT unit with gradual hand over

  • Full hardware and software upgrades and replacements (3 year cycle)

  • Project duration (3-5 years)


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Impossible is not a fact, irrespective of size

only an opinion

Thank you!


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