FI Data Capture and Maintenance⚓︎
The Data Capture and Maintenance capability involves providing mechanisms:
- For businesses to register (and maintain) themselves as Regulated Entities.
- For businesses who have already registered as Regulated Entities to to submit (and maintain) transaction reports.
- For businesses to receive, respond to and submit correspondence. The majority of correspondence relates to requests and responses for further information in relation to a registration or a transaction report.
To support evidentiary requirements, all reported data and correspondence is required to be stored in its originally reported format with strong audit trails of precisely when the information was received and who provided the information.
Financial Intelligence Agencies generally provide both an
API for sophisticated/high volume Regulated Entities to automate regulatory reporting requirements and a
web application (i.e. online forms) for entities with lower reporting volumes. There has been very little innovation within this area over the past 20 years, with each Regulated Entity building custom processes to meet regulatory requirements. However more recently Regulatory Technology (RegTech) providers have seen an opportunity in this area to provide services related to "regulatory reporting" to the financial industry. Significant business transformation is expected in this area over the coming years.
Reported Parties (Collection of Identification Tokens)⚓︎
As mentioned earlier the data collected across transaction report types and Regulated Entity registrations has different characteristics however the central concept is around one or more parties associated to an activity. A party is a collection of identifying tokens that is used to attempt to uniquely identify a "real world party" (e.g. names, accounts, phone numbers, birth dates, etc...). This collection of characteristics is called a
reported party. Below is a graphical representation of a reported party. In this example the reported party has a name, birth date, address, telephone number and bank account.
Generally within an individual business a universal unique identifier is associated with a party which links all of their details together (e.g. a Customer Id), however across the financial system and across countries there is no such identifier. Things would be a lot easier for financial intelligence analysts if there was one universal Id that identifies every business or individual across the world - however that would probably be a little scary also.
Reported Party Complexity Example⚓︎
To illustrate the complexity involved, a financial intelligence agency may receive three different reports related to the same "real world party", on the same day however all of the reported identification tokens may be different. The below table and graphic provides an illustrative example of how a customer (not even trying to subvert detection) may be difficult to identify as the same "real work party".
|Financial Inst. A
|Financial Inst. B
|Financial Inst. C
|John P Smith
|4 Wood St Sydney
|Unit 1 / 4 Wood Street Sydney
|1/4 Wood Str NSW Sydney
Adding further complexity, the collection of identifying tokens for a "real world party" also changes over time. Eg. names, address, phone numbers all change over time.
Supporting Data Capture⚓︎
The Data Capture and Maintenance capability additionally includes the capture of the following information to support data processing and access:
- Previously generated Financial Intelligence (for example watchlists or information reports). Allowing Financial Intelligence agencies to leverage historical analysis in future analysis activities.
- Supporting datasets such as exchange rates or financial system reference data (e.g. institution code to name mappings) that assist in the processing and analysis of reported data.