Case Study - Controlling Data Sources in Financial Crime MI Reporting

Problem

Partway through the implementation of a financial crime risk management insights framework with a client, we discovered that:

• A significant financial crime risk data input system was in scope to be replaced without buy-in from all end users of the system.
• A significant number of existing and planned MI insights would not be available in the short to medium term resulting in manual workarounds for the financial crime teams impacted.
• Those previously available insights would now be manual instead of being automated directly from source system.
• The additional resource requirement was not aligned with existing staffing levels within the firm.
• Most downstream data feeds would be impacted by this change.
• The vendor’s implementation team were working to an off-the-shelf rather than targeted implementation. Assurances to senior management of the same data provision as before without the analysis to support such claims proved to be unfounded.

Solution

• To address the challenges, Beyond MI were able to leverage their tailored data dictionary to establish all data points sourced from the system and produce specific data requirements to the vendor.
• This ensured that the Financial Crime function had:
  • a seat at the table to set specific requirements to ensure that all processing and insight capabilities were captured.
  • MI and other data requirements were included within the minimum deployment criteria to ensure that data feeds were in place and tested prior to system sign-off.
• Critically, the Financial Crime function could then work with the vendor implementation team to:
  • parallel run old and new system outputs to ensure consistency and accuracy of data produced.
  • establish a data ownership model for ongoing provision of financial crime related data.
  • establish data quality control points for existing data provision and planned enhancements.

Impact

The implemented solution has resulted in significant positive outcomes for the client:

• Uninterrupted provision of critical data from source system to MI reporting for Board, ExCo and MLRO.
• Continued insights into the quality of data contained within management reporting.
• Diligently planned data provision working from the Beyond MI established data dictionary for complete and accurate provision of data from source systems.
• All financial crime processes and downstream users of data being aware of the changeover and planned accordingly.
• Financial crime function inclusion in firm’s change control processes.