Guidance through the investigation triangle and how the principle of the triangle is fundamental to sound BSA/AML program compliance.
The exact requirements for completing an investigation are generally undefined by definition. After all, there is no one fit solution that can accommodate the vast array of nuances associated with suspicious activity. Essentially, the onus is placed on the organization to establish investigation and SAR narrative sufficiency. However, while there may not be exact requirements, there are exact principles that can and should be applied. Applying these principles is about understanding triangles of investigation such as (1) what we expected, (2) what we found and (3) what differences were exhibited that give rise to investigation and potential SAR filing.
Financial institutions must have employees that are familiar with the answers to this and other related triangles. Moreover, when investigations fail, it is often a byproduct of failed foundational elements needed to properly complete the triangle. For example, weak CIP and CDD will expose an organization in answering the first question because that organization never established this element. No investigational skills can resolve such gaps, but allow organizations needed emphasis to close those gaps as soon as practical. Moreover, a weak monitoring system leaves the organization’s second leg of the triangle in jeopardy of failure and again, this is often outside of an investigator’s domain. But, when these first two angles are established, it is on the investigator to close the third and this requires perhaps the most skills.
This webinar is about presenting the need for all three angles. It provides a basis for how CIP/CDD and EDD flow into the investigation. How monitoring through automated and manual systems provides a critical element to the investigator and then how the investigator uses those elements to build on a complete investigation. This webinar focuses on meaningful elements needed to complete the investigation and a tool for evaluating from a quality control perspective the strength of the investigation and potential SAR submission. While no QC can or should provide 100% coverage, it should utilize tools aimed at providing meaningful feedback to the investigator that promotes education and improvement. With this knowledge, an institution can expect its personnel to more effectively complete robust investigations and craft powerful suspicious activity narratives.
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