A volatile, global business landscape continues to contribute to shifting sanctions lists and broadening definitions of what constitutes a financial crime or regulatory violation. Concerns or infractions related to various sanctions requirements can trigger complex and sensitive internal investigations and government enforcement actions that are extremely difficult for corporations to navigate and respond to.
While sophisticated screening technologies and processes aim to address potential sanctions violations near inception, thus helping to reduce risk via proactive compliance enforcement, they do little to aid in retrospective investigations. This leaves organizations with an unclear starting point for meeting requirements to thoroughly examine internal and external communications across various channels, document libraries, invoices, customer databases and accounting systems.
Searching for the appropriate universe of potentially relevant information, eliminating false positives and building valid connections between millions of pieces of information is often problematic, especially when it’s necessary to search for hundreds or thousands of terms that include sanctioned entities or categories that are likely to yield overly broad results.
In one such investigation, our client needed to analyze thousands of entities, contracts, related documentation and thousands of transactions for each to look for potential and alleged sanctions violations. The relevant period covered several years’ worth of data, as well as present, ongoing transactions. Several of FTI Technology’s experts, who are an integral part of the firm’s data innovation lab, delivered efficient and repeatable solutions to conduct transaction screening using analytics, dynamic document connections and sampling for added quality control.
The team delivered the following solutions to support the investigation:
- Analytics: To overcome the limitations of standard search technologies — which provide limited insight into corresponding hits — all search terms, derivatives and corresponding hits were distinctly identified, counted, grouped and reported for interactive review. This enabled subject matter experts to efficiently screen thousands of transactions that were highly suspected to be false positives in minutes, and in turn helped the legal team eliminate hundreds of thousands of false positives in a fraction of the time it could have taken using conventional methods.
- Dynamic document connections: Relating customers and transactions across unstructured data, information from emerging data sources, various communication channels, contracts and other documentation poses a similar challenge, particularly when the pace of daily business nearly guarantees inconsistent filing and naming conventions. Using bespoke methodologies, search results were assigned scores and prioritized for review. As a result, dynamic and inclusive datasets of structured data and related documentation were unified for evaluation.
- Sampling: To bolster quality assurance across a large team of reviewers, a customizable sampling schema was implemented. The solution enabled supervising attorneys to tune the accreditation of each reviewer and thereby control the sample size deemed appropriate for validation.
Advanced digital engineering for accelerating digital risk
FTI Technology’s data innovation lab is dedicated to ongoing solution development that addresses the full spectrum of Digital Insights & Risk Management needs. The powerful combination of global subject matter expertise, interactive consulting and technical engineering enable key stakeholders to navigate financial crimes investigations more confidently, as they’re empowered by visibility into critical data.
Please contact us anytime and look forward to ongoing updates about new solutions from our data innovation lab.
The views expressed herein are those of the author(s) and not necessarily the views of FTI Consulting, its management, its subsidiaries, its affiliates, or its other professionals.