Case Study: Continuous Customer Monitoring

The Problem

Persons and entities are constantly being added to sanction lists such as OFAC and World-Check. If you only screen new customers you open your institution to the risk that an existing customer has been added to a sanction list. For this reason Truth Technologies, and OFAC, recommend that you re-screen your entire customer base on a periodic basis. See the Office of Foreign Assets Control (OFAC) Compliance case study for details on OFAC's recommendations

The Solution

Customer Monitoring, also know as re-screening, customers against changes in a Sanction list is a vital part of any compliance program. Re-screening can be done in one of two ways: periodically you can submit your entire customer list to be checked against the current copy of the relevant Sanction list(s), or you can have your entire customer list automatically checked when ever the Sanction list changes. Sentinel supports both methods of re-screening.

Re-Screening Customers

To re-screen customer you must use the New Data Alert (NDA) or Continuous Customer Monitoring (CCM) process.

New Data Alert (NDA) - The NDA process requires that you upload a new batch to Sentinel with a complete and up to date list of your customers. The default functionality of the New Data Alert (NDA) features compares current and previous applicant or customer screening risk results based on account number or other unique identifier supplied by you the client. If a previous customer match exists that has the same account number and matches the same watch list data a Duplicate risk result is produced. This saves you the time of having to remediate matches where none of the underling data has changed.

Checking for new data based on customer account number is adequate for most clients except in situations where the account number supplied is not unique, for instance there are multiple names associated with a single account number. In these situations the NDA process can be modified to compare customers using both the account number and the customer name. This feature is enabled by setting the "use customer name match NDA" preference.

Continuous Customer Monitoring (CCM) - The CCM process takes existing customer data in Sentinel that is marked for monitoring and re-screens the data against changes to the World-Check data base.. You may choose to be notified by e-mail if any matches are found.

What is the difference between the New Data Alert (NDA) and the (CCM) process?

Both the NDA and CCM process allow you to check customers that have already been screened against changes in the Sanction lists. The differences between the two processes are the requirements for entering data and the underlying data sources that support the process.

If the NDA process is used all customer data must be provided before the process can run. This is usually done by submitting a new batch which contains all current customer data.

If the CCM process is used existing customer data in Sentinel that is part of the CCM process will automatically be re-screened. You may choose to be notified by e-mail if any matches are found.

The Benefits

• Remain in compliance with OFAC and other AML regulations
• Fewer matches reduce the time spent reviewing matches - Only matches that result from a change in the underlying data appear