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Increasingly, financial regulators have been requiring institutions to implement transaction monitoring look-back projects to remediate any shortcomings in their Suspicious Activity Reporting programs. Look-backs often entail reviewing the universe of transactions that have passed through the institution for time periods ranging anywhere from six months to three years. While conducting a look-back is a monumental undertaking, it also provides the bank a unique opportunity to deepen its understanding of its overall money laundering and terrorist financing risk while at the same time lessening the likelihood of stringent regulatory actions in the future.
HOW CAN DAYLIGHT HELP
Daylight professionals have performed numerous regulator-driven transaction look-backs comprised of the risk assessment of hundreds of millions of transactions and tens of thousands of investigative cases. We can customize a risk assessment tool and case management system to identify potentially suspicious transactions and prepare investigative cases to facilitate the look-back review. Additionally, our professionals can assist with the investigations, provide quality assurance of the review, participate in meetings with the representative regulators, or provide turn-key solutions overseeing the entire transaction monitoring look-back review process. Of the many hurdles facing a financial institution tasked with a look-back project, office space, computer networks and information security are the most critical. Daylight has over 17,000 square feet of dedicated workspace exclusively for the performance of look-backs and similar, labor-intensive projects. Daylight is committed to taking all necessary precautions to secure client confidential data in accordance with statutory, regulatory, and industry standard best practices.
The look-back space is a high security environment with extensive physical and logical security measures in place including access control systems, surveillance cameras covering all exterior entrances areas and other priority areas including the look-back, server room and the evidence vault. Access to all exterior doors and high security areas is controlled by card key access. This infrastructure has been designed to comply with Gramm-Leach-Bliley as well as National Security Agency and National Institute of Standards and Technology standards. Furthermore, our physical, technical and operational infrastructure, procedures and processes have all been successfully reviewed and tested by security experts specializing in providing information security services to U.S. Government intelligence and defense agencies, financial regulators and global financial institutions.
Our overall methodology for assisting financial institutions with a transaction look-back can consist of multiple stages including:
- Data Normalization
- Risk Assessment Scoring
- Case Creation
- Investigation
- Quality assurance reviews
- Management Reporting
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