Page 95 - ACAMS-Today-V20N3

Geographic aspects
Typically, livestreaming is facilitated in a country from the developing world, while the activity purchased or viewed and the funds remitted are from developed countries. However, perpetrators sometimes use online money transfer agencies to send the money via another jurisdiction.
Analysis of financial data
Sharing keywords and financial indicators with financial industry partners has improved the quality and quantity of suspicious activity reports (SARs), and enabled financial intelligence units (FIUs) to identify and take action on these reports in a timely manner.
The data analytics by a bank
An intermediary bank, or a retail bank with a sizeable remittance activity with the Philippines,4 could analyze its outgoing wire remittances to the Philippines by running a data request of their trans- action data repository based on the following criteria:
• Defined time scope: Past 12 months
• Defined types of wire remittances:
—— All outgoing wire remittances to the Philippines from originators who are individuals (i.e., remove suffixes from the names suggesting an entity, including LLC, Pte, Inc, PvT)
—— All outgoing wire remittances to the Philippines, and to benefi- ciaries who are individuals
• Defined amount: Equal to or less than $1,000 (single or aggregate)
• Defined keyword search in Field 70/ purpose of the MT103s such as:
—— Gift
—— Treat
—— Birthday —— Invoice —— Expenses —— Fees
AML investigation
The extracted data is first reviewed, then the information is added to complete the originator and beneficiary information, to ensure that the data of wire remittances relates to person-to- person (P2P) payments.
The completed data is then reviewed against the bank customers’ profiles on file and the public domain to determine the relationship between the originator and beneficiary. For these cases, the AML investigator would also have to check social media to understand the relationship, if any, between the originator and beneficiary, to exclude legitimate remittances. Please refer to Table 1 for a list of scenarios warranting further review.
Table 1: Case study 1 and scenarios warranting further review
[ STAFF NOTES ]
INCLUDE IN THE REVIEW― POTENTIALLY RISK RELEVANT
EXCLUDE FROM THE REVIEW― NOT RISK RELEVANT
Multiple wire remittances to the same beneficiary
Regular wire remittances to the same beneficiary in the Philippines (i.e., likely family members)
Wire remittances from an originator with no apparent link to the beneficiary (in terms of name and ethnicity)
Wire remittances to probable family members in the Philippines (i.e., the name of the originator and the remitter are identical or both are Filipino names)
Multiple wire remittances in a month or over a six-month period from the customer (i.e., not consistent with profile and purpose)
Regular wire remittances once a month and almost on, or around the same day (e.g., end-of-month remittance when customers receive their salary from employers in the country of remittance)
Multiple wire remittances to the same beneficiary or from the same originator where the stated purpose is a “gift” or an “expense”
A check that shows that the beneficiary, their families or small communities are engaged in small enterprises and cottage industries (e.g., sale of handicrafts)
A check of the beneficiary in the public domain and social media that shows proximity of usually two or more young children with the beneficiary
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Sharing keywords and financial indicators with financial industry partners has improved the quality and quantity of SARs