Mitigating Weaknesses in Automated Surveillance Systems for Anti-Money Laundering Compliance | Exam Question Answer

Addressing Weaknesses in Automated Surveillance Systems for Anti-Money Laundering Compliance

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Question

An organization's automated surveillance system identifies large fluctuations in customer activity. As a result of an audit, the compliance officer is informed that the system is not generating alerts when activity is consistently abnormal over a long period of time. Currently the organization is evaluating new alert scenarios in an attempt to address this problem.

Which type of scenario is helpful in mitigating this weakness?

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The scenario that would be most helpful in mitigating the weakness of an automated surveillance system that is not generating alerts when activity is consistently abnormal over a long period of time is a "Peer" scenario.

A "Peer" scenario is a type of alert scenario that compares the behavior of one customer to that of their peers within the same customer segment or category. By identifying outliers within a customer segment, a Peer scenario can help detect abnormal behavior that may indicate potential money laundering or terrorist financing activity.

In the context of the scenario presented, the organization's automated surveillance system is failing to generate alerts when activity is consistently abnormal over a long period of time. This indicates that the system may not be effectively detecting long-term, subtle patterns of behavior that deviate from normal activity.

Introducing a Peer scenario would be helpful because it would enable the system to identify patterns of behavior that are abnormal compared to the behavior of the customer's peers within the same category or segment. This would allow the system to generate alerts for behavior that may otherwise go undetected, even if it is consistently abnormal over a long period of time.

For example, if a customer's transaction activity over a period of several months consistently deviates from the behavior of their peers within the same customer segment, a Peer scenario would flag this behavior as potentially suspicious, even if the individual transactions themselves may not have been flagged by the system.

In conclusion, a Peer scenario would be the most helpful type of alert scenario in mitigating the weakness of an automated surveillance system that is not generating alerts when activity is consistently abnormal over a long period of time.