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Copyright © 2006, SAS Institute Inc. All rights reserved.
Anti-Money Laundering Case StudiesDavid Stewart, CAMS
Director, Financial CrimesSAS Americas
Copyright © 2006, SAS Institute Inc. All rights reserved.
Session Overview
SAS Anti-Money Laundering® Customers• Sovereign Bank• BB&T• Bank of America
AML Enforcement “Horror Story”• Washington Mutual
Copyright © 2006, SAS Institute Inc. All rights reserved.
About Sovereign Bank
17th largest banking institution in the United States$ 90 Billion financial institution800 branches in 9 statesPrincipal markets in Northeast United StatesRegulated by Office of Thrift SupervisionNYSE: SOV
Source: www.sovereignbank.com as of March 14, 2007
Copyright © 2006, SAS Institute Inc. All rights reserved.
Investigation
High Risk Monitoring
Copyright © 2006, SAS Institute Inc. All rights reserved.
Unique Characteristics
Financial Intelligence Unit shares Data w/Loss Operations (Fraud) department
Unique Text String Scenarios
Business Analyst Function
3 million accounts monitored per night
30 Analysts / Investigators
Supervised Routing
ASP/Hosted Environment
Copyright © 2006, SAS Institute Inc. All rights reserved.
Sovereign Best Practices
Interactive Risk List Management
Advanced Analytic Techniques• Near Neighbor Detection• Link Analysis
Scenario Tuning
AML Data for Opportunity Management
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BB&TNinth largest U.S. financial services holding company
Total assets $122 billion as of 08/01/07
In the past 16 years, BB&T has acquired• 60 community banks and thrifts• 73 insurance agencies• 25 non-bank entities
Primary market segments are comprised of 50% retail and 50% commercial
Copyright © 2006, SAS Institute Inc. All rights reserved.
Copyright © 2006, SAS Institute Inc. All rights reserved.
Unique Characteristics
Transaction Monitoring team taking over Currency Transaction Reporting processes
First Customer to incorporate KYC scores into the monitoring process
10 million accounts monitored per day
10 Lines of business monitored
30 Analysts / Investigators
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Best Practices
Monitor ALL transactions through SAS AML
Strong Executive Sponsorship
Monitor Commercial accounts monthly
Scenario Analysis & Tuning
Manage Risk Lists for EDD
Copyright © 2006, SAS Institute Inc. All rights reserved.
About Bank of America
#1 Retail Bank in North America
Have a relationship with 1 in 3 US Households
$ 1.5 Trillion in Assets Under Management
65 million customers
Retail, Commercial, Private Banking, Global Corporate Investment Bank, Trust
Copyright © 2006, SAS Institute Inc. All rights reserved.
Unique Characteristics
30 million daily transactions
Monitor over 1 billion transactions per night
Investigations generated by • SAS Transaction Monitoring• Surveillance• Investigation• Field Alerts / Manual
45 Analysts / Investigators
25 +/- Scenarios
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Best Practices
Scaling large data volumes in Teradata
“Business Intelligence” Layer• Reduction• Triage
Team of SAS Business Analysts
Hit Rates
“In database” monitoring
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Washington Mutual
$ 355 billion in Assets Under Management
Regulated by Office of Thrift Supervision
Cease & Desist Order
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Deficient Processes
Failed to file SAR’s & CTR’s in timely manner
Controls for SAR decisions
CIP / Risk Scoring
Measuring Effectiveness of Monitoring
Aggregating Cash Transactions
Identifying Customer Relationships- Networks
Copyright © 2006, SAS Institute Inc. All rights reserved.
Questions & Answers
David Stewart, CAMS
Director, Financial Crimes & Compliance
SAS Americas
SAS Institute Inc.
T-4, SAS Campus Drive
Cary, North Carolina 27513
United States
919.531.6250
Copyright © 2006, SAS Institute Inc. All rights reserved.Copyright © 2006, SAS Institute Inc. All rights reserved.