Thursday, February 6, 2014 | 10:30 – 11:30 AM

Speakers:Kelvin Dickenson, Ron King, Allen Love, Ed Sander

Scaling FATCA’s Data MountainTechnologies and best practices to

streamline data collection, reporting and monitoring

Chief AML OfficerScotiabank

Toronto

Ron King

SVP, BSA Officer and Deputy Global AML OfficerTD Bank

Philadelphia

Allen Love

Global Risk Management SolutionsD&B

New York

Kelvin Dickenson

Global VP and General Manager, AML SolutionsNICE Actimize

New York

Ed Sander

• Focus is split on KYC and tax withholding– USFIs forced to act as tax withholding agents– FFIs revisiting customer due diligence programs

• Data availability & quality are huge concerns• Injecting FATCA ID w/in existing CDD processes• Regulation uncertainties still continue

– IGA network continues to evolve

What We’re Seeing In the Market

Areas Impacted by FATCA Regulation

FATCA Account Identification is Complex

• Avoiding regulatory and reputational impacts– Legal & financial penalties plus reputational risk

• Complex regulation significant business change– Overhauls ID of customers & beneficial ownership

• FATCA compliance > huge operational & IT impact• Data quality as lever to better customer insight

– New paradigm for managing customer information• Reality of future “FATCA-like” regulation

Business Challenges to Think About

• Review required for individual and entity customers:

FATCA Requires Comprehensive Review

What To Look For in a FATCA Solution

• Data capture: “Simplify”– Form-based with dynamic Q&A capability– Integration with on-boarding systems

• Data consolidation: “Complete 360 View”– Identity verification details & related account info.– Aggregate customer balance over multiple accounts

• Data enrichment: “Validate & Verify”– Auto-population of missing data; 3rd Party callouts

Data Management: Best Practices

• Data cleansing and enrichment: “Identify”– Customer identity discrepancies– US address validation

• IRS indicia detection: “Manage Change”– US account identification (pre-existing / new)– US ownership identification (pre-existing / new)

• Tracking and review: “Monitor”– Recalcitrant account status; Customer status changes– Documentary tracking

Issues Detection: Best Practices

• Automated and manual workflows– Letter creation/document request and response– IRS request management

• FATCA customer account classification– Identification of passive NFFEs* and beneficial

ownerships• Complete customer record

– Customer/entity profile info.; indicia alert details– Shows related accounts/entities and ownership

Investigations: Best Practices

*Non-Financial Foreign Entities

• Document capture: “Single-Point-of-Access”– Associate documents with customer record– Centralize documentary account / reference info.– Ability to Integrate w/document management systems

• Document tracking: “Flag Changes”– Manage & track document expiration (passport, etc.)

• Email integration: “Prepare for Audits”– Integrate emails/attachments as part of workflow– Ability to audit email exchanges

Documentation Management: Best Practices

Leverage CDD Investments for FATCA

Customer Due Diligence – A Cornerstone of Your

AML Program

FATCA Alignment with CDD

Knowing / understanding a customer Defining the acceptable business

context Understanding ongoing customer

relationship

Collection of customer information Customer classification Tracking of documentation and

evidentiary information Periodic reporting to regulators Ongoing review and verification of

customers

FATCA & CDD Common Capabilities

DataCollection

Customer Classification

Documentary Tracking

Periodic Reporting

Ongoing Review

CustomerRisk Ranking

Anticipatory Behaviour Capture

Customer RiskDetectionModels

Due DiligenceWorkflows

CustomerVerification

Document Request & Response

IndiciaDetectionModels

FATCAWorkflows

FATCA CDD

• Flexibility in your technology solution– You’ll need to run different modules & business rules– Different IGA agreements will require different

FATCA-related business logic and data elements

• Real-time services that are FATCA specific– Data verification across jurisdictions– US IRS indicia checks that are automated– FATCA determination status that is ongoing

Data Considerations for IGA/non-IGA

• Streamline existing processes for Account ID– Consolidate and enrich data across multiple sources

• Increase productivity and operational efficiency– Simplify applicant and ongoing client review– Automate document capture and reporting process– FATCA requires flexibility and extensibility in CDD

• Leverage to improve customer-centric approach– Centralized, comprehensive “single-customer-view”

Final Thoughts – FATCA CDD Benefits

Your Questions