5 considerations for evaluating financial crime systems

Tapan Shah, Elena Sutton, Abby Rosynek
| 7/16/2024
Professionals collaborate and discuss the best financial crime system for their organization.

The right financial crime system is critical. Organizations can make informed decisions by exploring options and considering five specific areas.

Inefficiencies, high false positive rates, limited detection capabilities, and feedback from examiners that a financial crime system does not align with the size and complexity of an organization can point to the need to upgrade or replace that system. Industry trends and other factors that can prompt an upgrade or replacement include regulatory scrutiny, new products and services, increased volume of customers and transactions, organizational growth via acquisitions, and aging systems.

Upgrading or replacing a financial crime system can help financial services organizations more effectively combat emerging threats, streamline compliance processes, and scale to the size and complexity of the business. But with so many approaches and technology vendors to choose from, how do decision-makers know which one is the right fit? Exploring different options and evaluating five specific areas can help illuminate the best path forward when upgrading or implementing a new financial crime system.

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In-house developed or vendor solution? 

At the outset, organizations need to decide whether to build a financial crime system themselves or turn to a vendor for a solution. Decision-makers must consider various factors, including the team’s technology skill set and experience as well as investment and maintenance costs related to people, processes, and technology.

While building an in-house system might be a strong option for certain organizations, many organizations choose to select a vendor-developed system. Often, organizations focus on and understand the level of effort required to build their own model but do not consider the time and resources required to maintain and support the model. With new regulations, additional products or services, or potential mergers, maintaining an in-house system can drastically hinder an organization’s ability to be nimble to changes and align systems to their risk profile. Getting bogged down in system maintenance can lead to significant cost and timeline overruns and negatively affect bottom lines.

If an organization has a proven track record of successful in-house model building and robust governance and it has an IT team that understands financial crime requirements, then pursuing an in-house system build might be the right path. However, if an organization lacks the necessary expertise or resources, a vendor system would be a more suitable option. Vendor systems can provide the flexibility to adapt to regulatory changes and support timely fulfillment of regulatory filing obligations. Moreover, vendors continually enhance their systems by incorporating the latest technological advancements.

Financial crime system vendor options

With numerous vendor options that provide a broad range of features and functionality, organizations can find it overwhelming to identify the system that meets their unique needs. Different vendors offer various options based on the type of system organizations need, such as customer due diligence, transaction monitoring, screening, fraud detection, and case management.

The marketplace of financial crime vendors is large, dynamic, and continually evolving. New startups are bringing innovative systems to the market, and existing vendors are expanding their offerings and capabilities. Given this evolution, it is important for organizations to determine which kind of vendor is the best fit for their financial crime programs. Organizations also need to decide whether they want a full suite that includes all financial crime models or if they only want to address a targeted need.

Generally, vendors fall into three categories:

  • Full-platform vendors provide a complete suite of financial crime systems.
  • Specialized vendors offer solutions in one or more of the financial crime areas.
  • Core banking system vendors provide add-on systems for financial crime programs.

5 critical areas to consider

Following are five areas to consider when evaluating which financial crime system to implement.

Compliance

Compliance is a critical aspect of any financial crime program, and the financial crime system an organization implements must meet regulatory compliance requirements for financial crime mitigation, data privacy and security, audit and reporting, ongoing monitoring and screening, and third-party risk management. Validation from independent third parties can help verify the effectiveness and reliability of the system.

Additionally, a financial crime system should be explainable so that users understand and can communicate the reasoning behind the system’s decisions and actions. Systems that lack transparency can make it difficult for stakeholders and regulators to understand how conclusions are drawn. While less transparent systems might offer advanced capabilities, they can pose challenges in terms of compliance and regulatory requirements because transparency is essential for both compliance and building trust in the system’s capabilities.

Organizations should proactively engage in discussions with their regulators, foster a collaborative environment to share ideas, and align on organizational objectives before selecting a new system for their financial crime program. Ongoing, consistent communication can provide organizations with industry feedback and help them successfully navigate choices in the marketplace and adopt new technology.

Capabilities

The capabilities of a financial crime system play a crucial role in a financial crime program’s efficiency and effectiveness. A basic workflow for a financial crime technology vendor should include alert escalation and triage, alert and case assignment, investigation, decision-making and resolution, continuous monitoring, and updates. Organizations also should consider any customization and advanced capabilities offered so that they can tailor the system to their specific needs. Add-ons include automated robots, AI narrative generation, and robust dashboards. An interface that is easy to use and follows a logical workflow supports user adoption and efficiency.

As organizations grow, their financial crime system needs evolve, too. It is essential to evaluate the system’s scalability to confirm that it can accommodate future requirements. Organizations should consider factors such as transaction and account volume, the number of users, geographic coverage, and the volume of data sources. They should also determine whether the system can manage increasing demands without compromising performance. Scalability is particularly important when operating in multiple geographies or dealing with large volumes of transactions.

Technology

When selecting a vendor, organizations should evaluate the underlying technology its financial crime system uses. Is the foundational technology aligned to current technology, or is it aging? Organizations might specifically ask about automation, which plays a pivotal role in streamlining routine tasks such as data entry, transaction monitoring, and report generation, reducing the risk of human error, and enhancing operational efficiency. Additionally, advanced analytics and machine learning algorithms can identify patterns and anomalies to continually improve a system’s effectiveness over time. AI-powered systems potentially can enhance efficiency, accuracy, and the ability to detect and prevent financial crime and fraud.

Organizations should also consider whether a cloud-based system, a software as a service (SaaS), or an on-premises deployment aligns better with their requirements and then inquire about capabilities that allow integration with existing systems and data sources. When choosing between on-premises, SaaS, and private cloud systems, important factors to consider include scalability, customization, cost, data ownership, regulatory compliance, integration capabilities, maintenance and support, security, and business continuity.

Track record

A crucial aspect of evaluating a financial crime system is assessing a vendor’s track record. Financial services organizations should seek a vendor with a solid reputation in the industry and a proven track record of delivering effective systems, which can be assessed by reports of successful implementations and client references. Peers and industry professionals can also provide valuable perspectives to help organizations explore potential challenges and benefits of working with specific vendors.

Organizations should also evaluate a vendor’s customer support services and the level of ongoing support and maintenance it provides beyond the initial implementation. Decision-makers can ask specific questions about the level of customer support service in terms of response time and dedicated call lines to facilitate quick resolution when needed. A reliable vendor understands the importance of offering robust support services that align with service-level agreements. It can commit to promptly addressing any issues or concerns that clients encounter during the use of its systems. It also acknowledges problems and actively works toward resolution to help clients effectively mitigate financial crime risks without interruption.

Evaluating the vendor’s commitment to research and development as well as its ability to stay ahead of emerging threats with the use of advanced technology is also critical when considering a vendor’s track record. By conducting a review of a vendor’s technology and its road map, organizations can select a vendor that meets their immediate needs and provides a system that can evolve amid the ever-changing landscape of financial crime.

Cost

Cost is a significant consideration when evaluating a financial crime system. The total cost of ownership should be assessed, including upfront investment, ongoing maintenance and support, and fees. It is important to consider the initial licensing, infrastructure, and implementation costs as well as the long-term maintenance and support costs. Such costs include annual licensing fees, ongoing expenses, variable costs based on use, resource costs for personnel or consultants, infrastructure costs for hardware and network, and training, customization, and enhancement costs. By carefully considering these costs, organizations can make informed decisions that align with budgets while meeting requirements across the other areas.

While cost is an important factor, it should be balanced with the value the system brings in terms of fraud prevention, anti-money laundering risk mitigation, and operational efficiency. A system that offers a higher upfront cost but delivers substantial benefits in terms of reducing financial losses and improving operational effectiveness might be a more cost-effective choice in the long run.

Investing time and making decisions

Selecting the optimal financial crime system can be a daunting task. By considering five critical considerations – compliance, capabilities, technology, track record, and cost – organizations can equip themselves to navigate the vast array of choices and make better informed decisions.

By dedicating resources and investing the necessary time to thoroughly evaluate and choose a financial crime system that aligns with their needs and long-term goals, financial services organizations can fortify their defenses against financial crime.

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