Automated Client Onboardingfor BanksOracle SOA & BPM Seminar, August 31st, 2011Excellence in Compliance and Document Management
Excellence in Compliance and Document Management
Excellence in Compliance and Document Management for 24 years and into the future…
• Founded in Switzerland in 1987• Profitable and independent for 24 years
• Customers in more than 45 countries• Headquarter in Givisiez / Switzerland
– Offices:• Vienna
• London
• Athens
• Singapore
– Key Partners– Actimize– Assentis Ltd. – Oracle– Tonbeller AG
Aug. 2011 Page 2
Excellence in Compliance and Document Management
IMTF’s value added is based on its financial services industry focusand experience in both Product Development and Project
Implementation
• Focussed offering in ECM and Compliance:“deep & narrow” vs. “broad & shallow”Integrated in your (banking) processes
• In-house developed “State-of the-Art” products for more than 23 years:Hyperdoc / Hypersuite / ZVx / etc.
• Integrator of complementary “Best-in-Class” solutions:DocFamily / SironXX / Oracle UCM / etc.
• Over 600 successful projects with proven expertise in complex technologies & productsIT integration and automation
Page 3Aug. 2011
Excellence in Compliance and Document Management
Today IMTF is the leading partner for Content Management and Compliance applications for more than 200 Banks (80+ in CH)
Page 4Aug. 2011
Excellence in Compliance and Document Management
“Client Onboarding for Banks” is an application to evaluate and manage the customer’s risk at the account opening stage:
• Customer due diligence: comply with regulations
• KYC (“Know-your-Customer”): relevant and sufficient information about the potential new client
• Integrated Checks: against sanction lists, PEP databases, etc.
• Process & control: rules, actions, audit, documentation
Page 5Aug. 2011
Excellence in Compliance and Document Management
This application is part of IMTF’s SironAML-Suite - a comprehensive and true end-to-end Anti Money Laundering Solution
Page 6Aug. 2011
Excellence in Compliance and Document Management
The application is offering a rich functionality for identificationand verification of a client and its risk:
• Professional tool for developing and layouting dynamic “Know Your Customer”customer acceptance questionnaires
• Customer information capturing including situation-depending variants for the questionnaire and real time Risk Rating
• Interfaces to 3rd party applications such as CRM, Core Banking System, etc.
• Watchlists, Blacklists and Sanctions List scan and PEP screening
• Configurable workflow
• Business rules for risk rating and actions to be taken
• Deadline expiration management (e.g. ID expiration)
Page 7Aug. 2011
Excellence in Compliance and Document Management
The (ongoing) Customer Risk Rating is calculated on factual information such as customer identity information, behavior
related and transactional elements:
Risk ScoringCustomer Identity Customer
BehaviourRelationships
Identity discrepanciesGeographic locationsOFAC screeningPEP screeningOccupation / business
…
Customer historyDocumentation statusAccount behaviourChannels usedPrevious SARs filed
…
Ownership structuresBeneficiaries Signature rightsLink analysisLogical entities
…
Internal Data
External Data
Analytics
Risk Rating
High
Medium
Low
Risk based reviews & surveillance
Page 8Aug. 2011
Excellence in Compliance and Document Management
The main function of SironKYC is a flexible rule & policy authoring tool with individually definable risk levels and
actions:
Every 5th Year
Every 2nd Year
Every Year
?
3rd Party Application
Risk Rating
(can be defined individual)
Flexible KYCQuestionnaires and Business rules/actions
Unacceptable
High
Medium
Low
PEPCheck
SanctionsWatch Lists
BadPress
UltimateBeneficial
Owner
CustomerIdentificationProgram (CIP)
Customer not approved
Customer approved
Account Opening
ContinuousInvestigation
BlacklistCustomer
Page 9Aug. 2011
Excellence in Compliance and Document Management
The basis of this automated process is structured information (from the KYC questionnaire) about the customer:
Page 10Aug. 2011
Excellence in Compliance and Document Management
SironKYC includes an “easy build” tool for the developing and layouting of such KYC questionnaires
Page 11Aug. 2011
Excellence in Compliance and Document Management
During the onboarding process the application automatically performs checks against chosen watch/sanction lists, PEP
databases, …
• All applicable embargo regulations and legal requirements in order to identify “PEPs” (Category of high risk customers) are covered
• PEP risk segment is critical because several national regulations require its identification among your customers
• Standard interfaces to commercial PEP database providers (including World-Check, Dow Jones/Factiva, WorldCompliance, …) are available
• SironKYC PEP module provides this functionality by screening your customers’database through “your” watch-list
Page 12Aug. 2011
Excellence in Compliance and Document Management
The integration of SironKYC into your environement is comprehensive, both from a logical perspective as well as ……
Business & organization
Know your Customer (KYC)Customer Acceptance
Risk Assessment
Research
Security & Technology Usage
Trai
ning
& A
war
enes
s pr
ogra
m
Man
agem
ent C
omm
itmen
t
?
Statistics /Lessons learned
Processes Initiatives Policies …
EnhancedCDD
SimplifiedCDD
WLMMarketAbuseAnti-FraudAML/CTF
Database/ListProviders
PEP
WL/Sanction lists
Stock Information
Risk & ComplianceCockpit
Case Management & Reporting
(…)
Page 13Aug. 2011
Excellence in Compliance and Document Management
……. from a technical integration into an existing environment (via Web Services):
Siron®KYC 3rd PartyApplication
(Existing) Customer Acceptance System
Scenario A: SironKYC looks after the entire customer acceptance process
A
Scenario B: SironKYC looks after the screening process (as web service)
B
PEP List
Sanctions & WL
Blacklists (…)
Scenario C: KYC questionnaire is called via URL
C
Page 14Aug. 2011
Excellence in Compliance and Document Management
As a result, SironKYC ensures that new customers do not pose an unacceptable risk to your bank and provides the base for
ongoing Risk Rating
A. Dynamic KYC questionnaireB. Check against watch listsC. Collect documentsD. Enter expiration date ID
documentationE. Use of 3rd party applicationsF. Ultimate beneficial ownerG. Parent treeH. Escalation; EDD, 4-eyes principle
I. Deviation actual transaction behaviors with stated
J. Change of non-financial elements, country, etc
K. Calculate new risk level, if increased generate alert
L. Create alert for Compliance/Account manager
M. Assign to employeeN. Perform EDD, 4-eyes
principle
O. Create alert for Compliance/Account manager
P. Assign to employeeQ. Collect new documents, add
new expiration date
Ongoing customer due diligence (Siron®AML)Account Opening (Siron®KYC)
1
Account Opening
2
Determine initial risk(A - H)
3
Customer approved/not approved
4
Monitor customer behavior
5
Check statedbehavior with actual
6
See [5]
7
Change in customer behavior compared to stated
8
Re-Calculation of the risk(I - K)
9
Increase Risk (L - N)
10
Expiration dateidentificationdocuments(O - Q)
11
continuous control monitoring
Page 15Aug. 2011