So, you’ve got your matching algorithm and you may have applied some False Positive Reduction (FPR) tools and techniques. But, you still have some matches left that you need to research and make conclusions about. How do you organize and process them? By having some sort of workflow functionality in your screening system, of course.
Workflow involves, at a bare minimum, the following:
- A way of organizing new matched records
- A way of moving records along a path from initial research, to one or more approvers
- A way of, at the very end of the process, organizing items that were false positives (looked like a match, but was not) and true matches
That is a bare-bones list. A more robust screening system should also support:
- Ways to document the research performed and the justification for the decision made
- Ways to notify external parties of actions taken (e.g. for Compliance Officers who only log into the screening system in specific instances)
- Robust real-time MIS dashboards and reporting
Making the system conform to one’s risk management standards also requires a design that can be configured to segment the work (e.g. along geographic or business unit lines), and to control access and visibility of the work.
I will cover all these in subsequent, bite-sized posts. As you may have noticed, this is all me.. no Gemini involved – I’ve had exposure to a lot of workflow systems in my day, both when I was a sanctions nerd and, before then, a wholesale payments nerd.
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