The world of AML and Sanctions compliance is changing dramatically. Today, compliance professionals must have a robust understanding of data, specifically the data used to manage compliance risk. No longer is it only the case of being a data owner and granting access to relevant compliance data but now, to use data governance terminology, there must be a data steward to oversee relevant compliance data. The data steward must ensure the quality of the data used in compliance risk management and also have the ability to address, through the mustering of all appropriate resources, data quality issues when found.
Further, today it is not just the issue of data quality within the model and filtering programs but rather the data quality in the processes of data gathering at the point of entry into the institution through the Extract, Transform, and Load ("ETL") processes from that initial point, the transfer into and out of any systems, datasets or databases, and ultimately the loading of that data into the monitoring and filtering systems. In fact, it carries through to the point in each decision on alerts generated in the AML model or Sanctions filtering programs
This has resulted in many organizations, when implementing their data governance framework in accordance with or guided by the Basel Committee on Banking Supervision, Principles for Effective Risk Data Aggregation and Risk Reporting, to initially focus on AML and Sanctions data and related processes.
ICRM can assist you with establishing your data governance framework or integrating your AML and Sanctions data and processes into your existing framework. Specifically, we can:
Assist in Development of Data Governance Framework
Assess/Benchmark Existing Data Governance Framework
Evaluate Ability of Data Governance Framework to Enable Strategic Success
Assess Data Quality/Data Flows Including Data Controls
Evaluate Roles and Responsibilities Against Incumbent Expertise
Assess Data Access and Use to Achieve Strategic Success
We can also assist you in addressing concerns raised during assessments, independent tests, model validations or regulatory examinations associated with AML and Sanctions data and data governance.