Handbook of Anti-Money Laundering.

CHAPTER 26MONEY-LAUNDERING-DETERRENCE SOFTWARE

26.1 WHAT IS MONEY-LAUNDERING-DETERRENCE SOFTWARE?

As part of a firm's obligations to combat money laundering, they often decide to invest in the use of anti-money-laundering software. Anti-money-laundering software is essentially a computer program designed to analyse and record customer data, and detect suspicious transactions. Some of the main providers of anti-money-laundering software (highlighting their owners, where relevant) include Actimize (NICE), Ambit (Sungard), Mantas (Oracle), Fiserv (formerly NetEconomy), Fortent (formerly Searchspace, also NICE), Norkom and SAS.

There is no single approach to the way in which such software operates, although the products do fall into two broad categories. The first is the scenario-modelling approach and the second the inference-based approach.

Of course, there is no specific requirement for a firm to implement money-laundering-deterrence software; the regulations are not that specific. If a firm has a limited number of clients and already knows its clients well, then there may be little requirement leading to such investment. However, the problem with the due diligence conducted by an individual is that it could either be biased or poorly documented. Money-laundering-deterrence software serves to provide the firm with an audit trail that can demonstrate that it has taken the actions expected of it. So, while it is not a requirement, it is clearly in the interests of a firm to consider ...