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ISSUE
The New York Branch of a Foreign Bank was under heavy regulatory scrutiny. The Bank’s Internal audit had issued major audit findings across Transaction Monitoring, Know Your Customers/ Customer Risk Scoring, and Sanctions under the Bank Secrecy Act, USA PATRIOT Act, SR 11-7, and NYDFS Part 504.
Although the Bank had expended considerable resources on its Data Governance program, the program was in a nascent state not yet fit for purpose, and the client did not have a fully functional logical model.
The audit finding was co-owned by the Compliance Department, Data Office, and Information Technology.
ACTION
Exiger was retained under a very aggressive timeline to address the internal audit issues. We focused on reviewing, reassessing and revising the in-scope critical data elements, including the mapping between the business concepts and critical data elements.
To meet client needs, we divided the project into three separate workstreams: AML TM, KYC/Customer Risk Scoring, and Sanctions.
For each workstream, Exiger:
- Reviewed and reassessed existing conceptual data models and revised them where appropriate.
- Reviewed and reassessed the logical data model and revised it where appropriate.
- Reviewed and reassessed data quality rules, providing revisions and suggestions where appropriate.
- Conducted a gap analysis on the coverage of implemented data quality rules.
- Developed fully automated data quality checks.
- Designed and delivered fully automated SQL queries for all in-scope data quality rules.
- Provided work papers to document Exiger’s analysis and work product.
- Updated Data Governance program documentation.
IMPACT
Exiger delivered on all requirements of the project despite the aggressive timeline. Exiger’s deliverables were determined to directly address the audit findings and substantially increased the coverage of data quality monitoring.
The Bank now possesses a fully automated tool to serve as a foundation for future data quality monitoring efforts.
