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Using Search Engines For AML Compliance…..????

25/10/2019

Search Engines have transformed people’s everyday lives.  We can instantly find the best Italian restaurant in town, directions to the airport, and what the cast of Saved By The Bell is now doing.   Search Engines are not, however, AML compliance applications.

This may sound surprising to tens of thousands of AML analysts and investigators around the world who rely on Search Engines like Google, Bing and Yahoo to find negative news information about customers, counterparties, and other people and companies they are researching and investigating.

Relying on Search Engines to find negative news information is a big problem because:

  1. Search Engines do not find all negative news information
  2. Search Engines present way too much unrelated information
  3. Search results needed by AML analysts are often buried well past page 1
  4. “Search Strings” used by AML analysts are helpful but highly limited
  5. Search Engines add time to AML work and increase costs
  6. Search Engines provide no record of work and therefore no proof to auditors or regulators

Search Engines Do Not Find All Negative News Information

Search Engines find information on the Surface Web, the part of the Web available to the general public.  There are billions of pages of information on the Surface Web.

When an AML compliance analyst wants to locate negative news information, a portion of these billions of pages are reviewed by whatever Search Engine they use.  Each Search Engine contains different indexes of information gathered from the web.  So Google, the most used Search Engine, does not search all the same information Bing or Yahoo search.  So just using Google means an AML analyst may miss negative risk information.

Google (or Yahoo or Bing) may in fact “find” the information that an AML analyst needs, but that important result – the one the analyst needs – may be on page 12.  In these cases, it is highly unlikely the analyst will read the first 11 pages of results, thus in effect the information needed by the analysts is never found.  Read about a real example of this here

Search Engines combine hundreds of factors into complex algorithms that try to find information about each search query.  The problem is, no-one knows how these algorithms work – they are the closely guarded property of the Search Engines.  Not knowing the logic and computations behind a Search Engine’s algorithms puts AML users in a bad spot; analysts are left with the uneasy feeling that they may be missing key information.

Irrelevant Results and “Search Strings”

Search Engines are designed to show what they think you want to see.  Problem is, they don’t actually know what it is you want to see.  They don’t know you are an AML analyst looking specifically for information about whether a customer was involved in a past legal or criminal matter.  So Search Engines, using their algorithms, give you lots of information that isn’t relevant to what you want.  This means scrolling through endless results trying to find the one or two that actually matter.

These unrelated results add time to an analyst’s work, which piles up costs for each due diligence and investigation case.  Unrelated results also increase risk.  After-all, how many results can a person look at hour after hour, day after day, and not become frustrated and distracted by the monotony.  No doubt, this leads to analysts missing critical information.

To address the problem of too many unrelated results, analysts devise “search strings” of negative terms that try to reduce irrelevant information.  Search strings often do reduce results but they also create other problems for AML compliance.  Here are two of those problems:

Search Engines limit the number of words that can used in a search string.  What if the words not included are the words that would find the key information?

Search strings are not consistently used by every analyst on every search, thus creating an environment where work is done differently by everyone on every matter.  This lack of consistency leads to non-compliance.

No Proof of Work

Negative news searching is a critical component of AML due diligence and investigations.  Any strong AML compliance program requires work be documented and saved for review by a manager, an auditor and the regulators.  Search Engines do not provide any features that enable AML users to properly and consistently document their work.

AML procedures may mandate taking screen shots or copying and pasting the first page of Search Engine results, but in many instances this doesn’t prove much.  A screen shot won’t capture the entire search string used, or it won’t capture page 2 – 10 of the results.  It is also a mundane and monotonous process that is prone to human error

If you are an AML compliance professional, it is important that the tools and applications you use are effective, efficient and consistent.  Using Search Engines as a way to find negative news falls short on all three of these objectives

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