In a 2016 Global Economic Crime survey, PwC revealed global money laundering transactions are estimated at $1-2 trillion annually. The United Nations Office on Drugs and Crime (UNODC) believe less than 1% of global illicit financial flows are currently seized by authorities.

Other relevant facts revealed in the PwC survey included:

• More than one in three organisations have been victimised by economic crime
• Cybercrime is the second most reported economic crime impacting organisations
• 1 in 5 financial services have experienced enforcement actions by a regulator

goAML is an integrated software solution developed and maintained by the UNODC, specifically for use by financial intelligence units (FIU) around the world. The solution provides intelligence analysis, while having the ability to process business requirements. Hence FIC chose goAML as the preferred system to handle the reporting, data collection, analysis, case management and secure communications required for its daily operational functions and requirements.

The bank volunteered to run with a pilot, to allow other South African banks to learn from their goAML implementation and thereby create a reference for the industry.

The project was split into four phases and successfully achieved the following:

• Phase 1: Gap analysis – system-focused and included data mapping, high-level implementation plan and recommendations for participation in the pilot
• Phase 2: Phased pilot which included all of the client’s business units and accountable institutions reporting relevant transactional and customer information for all product types. This involved the testing of the FIC connection with the bank and reporting null values for the data not yet implemented
• Phase 3: Full solution roll-out of all impacted interfaces, processes, systems and artefacts, achieved with zero defects. Submission of data to the new data warehouse from the different franchises and the reporting of CTRs, STRs and TPRs from this warehouse
• Phase 4: Implementation of the IFTR (International Funds Transfer Reporting) requirements, which included updating of the Product Codes and Function Codes to include cross-border transactions and submission of test data to the FIC.

A senior stakeholder at the bank advised that BSG did exemplary work on this project and played a key role in quantifying and enabling the change to goAML. “BSG are the big picture partners we want and they consistently exceeded expectations. Despite pushing the team and always demanding more, BSG delivered far more than was committed, showing great practicality and a flexible approach.”

The training guides BSG developed were submitted and reviewed by the Regulator, who advised these are the best they have seen to date and will be using them as the baseline for other South African banks.