Second Pillar Consulting applies expert knowledge about Anti-Money Laundering (AML), Office of Foreign Asset Control (OFAC) screening, and model validations to transaction monitoring, name screening, and customer risk scoring models. Our unique approach unlocks the “black box” of AML models and ensures that our validations meet regulatory expectations. Our experience with a range of AML platforms (Abrigo’s BAM+, NICE’s Actimize, FIS’ PRIME Compliance Suite, FiServe’s AML Manager, Oracle’s Mantas, GlobalVision Systems’ Patriot Officer) helps you identify your risks and ensures your systems are appropriately implemented and calibrated to capture these risks.
Our Expertise & Experience
Program & Governance Review
Validation & Implementation – We ensure that our validation and your implementation meet regulatory expectations (Compliance with SR 11-7, Bank Secrecy Act, PATRIOT Act, and FFEIC Examination Manual).
KYC – We assess the Know Your Customer (KYC) process to ensure compliance with regulatory requirements and industry best practices.
Replication – We replicate the logic for every monitoring strategy, for all product and customer types to ensure the AML model is operating as intended and alerts are accurately reported.
Calibration – We ensure appropriate thresholds are used in transaction monitoring and are defined using a reasonable approach. We validate thresholds by evaluating alert performance and conducting above-the-line/below-the-line testing.
Methodology – We evaluate the scenarios and typologies implemented against the BSA risk assessment to identify any gaps in transaction monitoring.
Benchmarking – We validate “black box” solutions by benchmarking results against our proprietary model to ensure the solution is operating as intended.
Calibration – We ensure appropriate thresholds are used and defined using a reasonable approach. We perform sensitivity analysis to evaluate the appropriateness of thresholds.
Methodology – We evaluate the model’s methodology against the BSA risk assessment and ensure compliance with OFAC, FinCEN Section 311, and other watch lists.
Customer Risk Scoring
Replication – We replicate the customer risk scoring methodology to ensure the model is working as intended.
Calibration – We perform sensitivity testing and benchmarking to evaluate the appropriateness of thresholds and inputs used.
Methodology – We evaluate the risk scoring methodology used to ensure it aligns with the BSA risk assessment, regulatory expectations, and industry best practices.
Accuracy – We verify that the data extraction, transformation, and load process accurately imports data from source systems.
Data Mapping – We reconcile the transactions in the source systems to the transactions monitored.
Information Loss – We evaluate the flow of data from source systems into the model to ensure data is being included in the model as intended and no records are being unintentionally excluded.