Crédit Agricole Indosuez recently signed a contract to install Americas Software's transaction monitoring customer knowledge system at its private banking offices. The money laundering detection system, known as Assist//ck, is a Windows-based product that lets financial firms manage suspicious account activity through transaction trend monitoring.
The system, developed by the Miami software house, allows banks to create client profiles based on transactional activity, and provides daily, weekly and monthly reports of suspicious account activities. The bank can also choose to define suspicious accounts in terms of branch, officer, updates, transaction type or country of origin. It is the first time CAI has implemented such a system.
CAI's private banking business is organised around four main European locations, France, Switzerland, Luxembourg and Monaco. It has more than €42bn under management and employs 1,000 staff. CAI also has significant private banking offices in Brussels, Geneva, Gibraltar, London, Milan and Madrid. Etienne Saint Raymond is the IT adviser to the director of private banking at CAI. He is also the IT project manager involved in setting up and installing Assist//ck at CAI. Complinet spoke to Saint Raymond yesterday to discover how the bank developed the project, from conception to roll out.
Complinet: Why did you set the system up now?
Saint Raymond: We decided to enhance our compliance duties last year, and by the end of spring we were certain that we wanted to equip our private banking units with software to help combat money laundering and fraud. During summer and autumn we conducted a survey to determine which vendor we wanted to work with, and we signed the contract with Americas Software in December.
We're in the process of installing the software, which will go live between May and July. We have to install it in various countries where our private banking operations are located, so we're working on a staggered roll out of the system. We want to learn from the first installation, and then roll the system out smoothly in the other countries.
Complinet Why Americas Software?
Saint Raymond: We conducted a survey [of AML software vendors] and discovered most of the vendors were US and UK companies that offered systems to these countries. Americas Software had a product for our private banking unit that wasn't too complicated. The search function was adequate, the system was user-friendly and the workflow between people wasn't too complicated, but allowed for a dual separation of tasks between the investigator, and the person checking the investigation. The quality of the audit trail in the product was good, and Americas Software sticks to the knowledge of the AML business, both in compliance and IT aspects.
Complinet What does Credit Agricole Indosuez hope to achieve by installing and setting up this system?
Saint Raymond: We want to have a more thorough view of our transactions, and automate the process more than it is in its current state to make it more comprehensive so that we can scan all transactions. We also want to have a tool that can examine a combination of various types of transactions that were made at different times, or disparate types of operations. We wanted to have a total view of transactions that you don't get on single view transactions so that we can spot suspicious behaviour.
Complinet What steps did you take to set up the system?
Saint Raymond: Step one was the survey I've already mentioned. The second step was the management's decision at the head office in Paris to adopt the system. The third step is now to roll it out on the first site. We have to create an interface between the mainframe and the server that the software sits on, and we can't do this at the same time in all of the different banks. The first phase of this step is to roll out the system in a pilot phase in our private bank in Monaco. Luxembourg and Paris will follow. We are also considering installing the system in some subsidiaries in France and in London.
The fourth step is the need for collaboration with other countries where our private banks are located. We have talked to management at the head offices, but we also had to talk to the staff working with customers in the banks to ascertain what needed to be done. We need this collaboration to set up a global policy regarding the use of the software, for example what kind of analysis they want to run. We're at the beginning of stage four now, and we have to put these specific policies in place regarding this kind of tool, because it's new for us.
This forth step will reinforce the policies already in place that include a thorough identification of a customer before entering into a banking relationship with them, and a follow up of transaction amounts, because the threshold amounts that have to be announced differ in various countries. We're also targeting specific operations which show a combination of suspicious behaviour and irregular transaction amounts.
Complinet What will this mean for private clients in terms of privacy and data protection?
Saint Raymond: We are installing a system at each private bank that will be available only to that bank. The day-to-day operations will be run locally by teams at the bank, and there will be no sharing of information among the sites so client confidentiality is preserved.
Complinet What level of involvement does Americas Software have in the running of the system?
Saint Raymond: They are involved in the installation stage, and in training the IT and compliance people to use the system. After the initial stage, they'll help to tune the system but they won't remain on site. Any further involvement from Americas Software will be maintenance and support functions and possible upgrades when they become available.
Complinet Is there an online component to the system?
Saint Raymond: So far, there is no online component. We have to download transactions once they have taken place in order to analyse them. We have not yet determined how often we will run such analyses, whether it will be weekly or monthly, as we will have to test the system first.
Complinet Does the system deliver batches of transactions?
Saint Raymond: Batches of transactions will be downloaded onto the server where the software is from the mainframe and then the people who check it will have restricted access to the information via passwords and confidentiality profiles.
Complinet Does the compliance officer determine the settings for what types of transactions you're looking for?
Saint Raymond: Yes.
Complinet How much does the system cost?
Saint Raymond declined to comment on the cost.