Three reasons why audit must be a part of your AML investigation process  

By Caroline Tatam


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    Open Source Intelligence (OSINT) is the process of gathering and analysing publicly available data to produce actionable intelligence. It’s a powerful weapon for any Financial Institution in the fight against crime. The effectiveness of regulatory compliance processes such as anti-money laundering (AML) and know your customer (KYC) relies on an in-depth understanding of clients and counterparties, risk actors and threats. By using OSINT, financial institutions can extend their investigations outside of siloed commercial databases and internal systems for a more expansive, up-to-date and proactive understanding of illicit behaviours, connections, and risks. 

    Having access to a comprehensive audit framework providing chain of custody for all evidence gathered in AML investigations is vital. Here are three reasons why. 

    #1 Proving compliance with regulations 

    Increasingly, regulators are scrutinising whether banks have taken appropriate action and completed thorough investigations to prevent business dealings with nefarious individuals.  

    A substantial proportion of fines for AML transgressions are related to due diligence failures. Having access to clear audit data gives banks the opportunity to prove to regulators that the appropriate level of due diligence was completed before a customer was onboarded. Audit data can prove that sanctions lists were consulted, a customer’s business relationships and company holdings were reviewed, and an adverse media check was completed.  

    Working with dynamic OSINT data can cause problems for investigators if the data is later removed from the internet. Having access to Videris’s audit framework means there is always a record of the information, even once it’s no longer available online. 

    #2 Preventing misuse  

    OSINT can be an incredibly powerful tool in anti-money laundering investigations. However, many organisations fear their analysts may be using OSINT – and any supporting software – for personal gain; to investigate personal contacts or acquaintances. Whilst regulators stress the need for compliance with anti-money laundering regulations, they are also concerned with possible breaches of data protection laws. Recent incidents have seen the Bank of Ireland, Morgan Stanley and others, fined for breaching data regulations. Balancing the need to allow investigators to examine publicly available data and the risks of abusing these privileges is a constant challenge.  

    Being able to access audit data such as search terms and target entities allows organisation administrators to ensure that their users are only collecting information directly related and proportionate to the remit of their assigned investigations. 

    Videris helps the analyst maximise the accuracy and relevance of collected information, but audit allows administrators to make sure their users are not misusing these tools. 

    Audit data can also be used to ensure all employees are adhering to your institution’s policies around legitimate use cases. 

    #3 Improving investigative consistency 

    Audit data provides a clear record of all the steps taken in each investigation. This can be useful when presenting that data to the wider business; or when revisiting a case, to be able to see what was covered in earlier investigations. 

    Having access to audit data means banks can review all investigative activity centrally to ensure consistency and that analysts are carrying out a satisfactory level of investigation for all subjects of investigation. 

    Often, different individuals or teams have different approaches to investigations. By reviewing audit data of existing investigations, banks can identify gaps and professionalise a process that can otherwise be disparate. 

    Videris provides audit tools essential to financial crime investigations 

    Videris provides administrators with comprehensive audit tools, allowing them to review activity at an action, user, or case level. Audit data is secure and can only be accessed by selected users at your organisation. This extensive audit framework has benefits for everyone involved in AML investigations: 

    • Heads of Financial Intelligence Units and Money Laundering Reporting Officers are reassured that Videris provides full chain of custody of all investigations, whilst maintaining control over how teams are using sensitive OSINT data 
    • Investigators and analysts can focus on completing investigations efficiently, without extensive manual record-taking 
    • Regulators can recommend the use of OSINT knowing protections are in place to ensure adherence to data regulations and avoidance of abuse. 

    To find out more about how Videris can support your OSINT investigations with audit, book a demo now.