A Systems Theory and Risk-Based Approach
Chapter 4: The Case Study of Drosia Bank
INTRODUCTION This chapter discusses the main findings from a case study that was carried out over a three-year period in a financial institution in the EU area. A confidentiality agreement between the author and the financial institution cannot allow for an in-depth analysis of the context within which it operates so that the identity of the institution is not exposed. The name of the financial institution and the names of any information systems that could identify the financial institution have been altered. The findings from this case study present an analysis of the internal reporting system of the bank, the increase in the number of suspicious transaction reports and investigate the influences of various information systems on AML. In order to structure the presentation of the findings better, the AML system of the bank is primarily analysed by utilizing the following distinction: 1. 2. Investigations into money laundering that are initiated by a request from the national Financial Intelligence Unit or a public prosecutor Investigations into money laundering that are initiated by the bank’s network of branches. Along the aforementioned lines, critical information systems that influence anti-money laundering work are discussed. These include (among others) a Case Management System (CMS) where data is stored for all ML investigations, an information system that is used to identify customers uniquely and a profiling software that attempts to capture suspicious transactions. ACCESS TO THE BANK Before beginning to describe the main findings of this case study, the author would like to express his...
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