We have partnered with 3Mindz Tech Limited to provide our clients with the Compliance Activity Monitoring Portal (CAMP). The aim is to assist financial institutions to improvise and automate their processes through modern technology. It is important that organisations showcase all the good work done, through impeccable audit trail and documentation.
CAMP is one of a kind solution and has several distinct features including KYC & adverse information screening, Regulatory Compliance Management, Complaints Management, Trade & Transaction Surveillance, Staff Conduct Monitoring, automation of manual compliance processes through a workflow system between staff and Compliance Officers, a single-view Dashboard for all outstanding alerts, an incredible reports module and an email notification system.
The system is based on best practices covering the entire case management cycle, from recording and managing the case components, to generating the output, and providing analytics and historical data. It is designed to complement the organisations’ existing technology infrastructure.
The system has a KYC module to document all client information and also conduct periodic reviews based on the risk classification of the clients. Ad-hoc reviews can be initiated should there be material change to the client’s profile including any negative information. All alerts, pertaining to the respective clients are displayed in the respective KYCs, for enabling the RM and Compliance officer conduct comprehensive due diligenceq
CAMP is a good adverse information screening tool that is able to identify, if a client is implicated with a crime just based on the description provided in the article. Every article is processed by an Artificial Intelligence tool called Natural Language Processing (NLP). It understands the sentiment if an article is negative or positive, if it’s related to law, enforcement or politics or otherwise. Through which the system reduces ‘false positives’ drastically. The system has a scoring model based on the confidence level of the article which helps the organisation to review alerts on a risk-based approach. It supports multiple language screening. It screens clients against information available on public domain, sanctions lists and internal blacklist that is maintained by Compliance.
The rule-engine that operates the surveillance scenarios are designed intelligently to identify potential cases related to market manipulation including insider trading, wash trades, front running by staff & clients and mis-selling. It also monitors high-risk fund transfers that originate from or sent to an exchange house, transactions between staff and clients that pose a potential conflict of interest, transactions that get rejected by correspondent banks for compliance reasons which will assist the relationship manager and compliance officers to conduct due diligence on the client from an AML perspective.
The system reviews staff telephone calls that are recorded by the organisation from an AML standpoint. Using Artificial Intelligence, the system converts calls to texts, identifies calls based on key words for potential breach of policy and alerts the Compliance officer should there be a match.
CAMP is a workflow system through which Staff and Compliance Officers can interact with each other and handle any request within the system. All advice and approvals, which currently are handled via emails or telephone calls will be initiated, replied and closed in the system.
All staff who are insiders or facing a conflict of interest situation, have an obligation to take approvals for any purchase or redemption of securities from their line managers and/or Compliance officer through this system. The system also monitors if a staff is front-running by matching these securities against transactions executed by clients.
All requests for approvals when giving or receiving a gift or entertaining clients or making political contributions can be managed through this system. It helps identify conflict of interest situations and records the actions undertaken by the organisation.
This system empowers staff to report suspicions to the MLRO, confidentially and can interact with Compliance (and vice versa) through this system. Also Compliance can investigate and document the results including if an external SAR is required to be filed.
All Regulatory communications including circulars, enforcement notices, rulebook changes, consultation papers and court orders which require action or otherwise, are recorded in the system. Through this we can identify the impact, any regulatory notice, would have on the internal policies.
All requests for approvals when giving or receiving a gift or entertaining clients or making political contributions can be managed through this system. It helps identify conflict of interest situations and records the actions undertaken by the organisation.
Internal & regulatory breaches when identified are recorded, investigated and corrective actions documented through this system including filing of a regulatory notification, if necessary.
It also helps in maintaining an internal blacklist of local sanctions, SARed clients, clients of unacceptable risk, rejected & declined businesses and clients investigated by the FID. Staff will be able to search their clients and related parties against this list through the list screening module, which every staff will have access to.
Training management can be done effectively through this system. It will initiate alerts for training and maintain records of attendance.
Minutes of client meetings can be recorded in this system. Minutes of governance committee meetings and any outstanding action points can be recorded with target dates.
All periodic staff declarations are initiated and reconciled through this system. This could be annual declarations or ad-hoc declarations as decided by the organization.
In CAMP, complaints management goes through various stages. First, information is received and recorded into the system. And an acknowledgement is sent to the client immediately. The system reports the case to an expert, that is, the staff in charge or Complaints Management Officer or a Compliance Officer as appropriate. Second, the authenticity of the complaint can be examined, explained and closed in the system with a clear audit trail and appropriate documentation. Finally, responses are provided to the complaining customer.
In CAMP, Data is stored in a structured manner. Hence, Information Reports can be extracted from the portal on a variety of subjects which will help the management make more accurate, data-driven decisions.