In our continuing series of TBML Commentary & Analysis, examining issues in the field of Trade-Based Money Laundering, the matter of a useful software platform to identify, in real-time, TBML transactions has come up. Given that there is really no clearinghouse in the AML/CFT compliance industry for such a program, and due to reader interest, we have taken it upon ourselves to search for a solution, if one exists. Our knowledge of legacy programs used in the past, which we found to be one-dimensional and not agile enough to handle the rapidly evolving subject, may guide us somewhat in what is not suitable or effective, but we trust that there's something out there which will aid compliance officers tasked with stopping TBML in their workplace in catching the bad guys in the act. That is our goal.
Our issues:
(1) FLEXIBILITY: Given that laundrymen who operate TBML pipelines are constantly fine-tuning and modifying their operations, the program must be adaptive to changing conditions. Does it contain sufficient data, and the ability to recognize something new when it encounters it?
(2) REDUCING FALSE POSITIVES: Will the program ignore legitimate transactions, and only cull out true potential TBML operations? To do so, it must have a sufficient knowledge base, including tradecraft, to separate the wheat from the chaff.
(3) IS THE DATA CURRENT, ACCURATE AND COMPLETE? Please, it simply cannot be using 2022 data, or some other similar information shortcoming. Does it feature frequent updating of its database?
My search has begun; I will be reporting back to our readers on my progress. Wish me luck.
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