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Continuous Monitoring & Reporting
Compliance & Fraud Monitoring
Banking SectorData2knowledge Inc.
Andrew Gonczi, CEO Data2knowledge, Inc.
www.d2k.com
16th World Continuous Auditing and Reporting SymposiumRutgers University, NJ; November 2008
Presentation outline
• About Data2Knowledge
• Continuous Monitoring Needs
• Banking Application
• D2K Secure, Continuous Monitoring System
16th World Continuous Auditing and Reporting Symposium - 2008
About Data2Knowledge
Corporate Overview• Established in 1999, offices in NJ, UK and Hungary • Specialized in continuous monitoring and financial data services• Blue chip corporate clients in US and Europe
D2K Distil• Key financial data found and extracted more accurately, faster and
for a fraction of the cost D2K Secure• Continuous Fraud and Compliance Monitoring
D2K Development• Offshore (Hungary) development and service team; Cost effective,
innovative• D2K's core extraction engine is also available to be embedded in
custom applications and as a SDK to partners.
16th World Continuous Auditing and Reporting Symposium - 2008
Continuous Monitoring Needs
Why is continuous monitoring becoming a must now?• Advances in technology and increased business dynamics enable
businesses to change ever more rapidly, • Traditional audits and controls are no longer adequate
Key drivers• Past few years’ events (9/11, malfeasance crisis, complex and creative
business models)• Subsequent regulations (HIPAA, SOX, Patriot Act, Basel II, MiFID, etc.)• Business needs, competitive development of controls to be matched
Benefits• Immediate notification to management of problems, timely correction • Fraud reduction and improved risk management• Extensibility across multiple IT systems • Independence from operative management
16th World Continuous Auditing and Reporting Symposium - 2008
Fraud prevention & Compliance needs
Key Drivers • Laws and Regulations• Direct P&L impact to prevent losses from fraud• Indirect P&L impact – business reputation, client retention and acquisition
Continuous Monitoring Requirements• To detect fraudulent, unauthorized or money laundering activities, operational
systems need to be monitored on an ongoing basis• All systems produce activity/transaction logs, but differing formats• Centralized Monitoring Dashboard gives clear view across all business
transaction and IT systems
The Audit Trail Imperative• Details of finest granularity needed at all times in near real time• Drill-down analysis required• Data Source Quality, Data Level Assurance• Proof for Internal and Public proceedings• Transaction level intervention
16th World Continuous Auditing and Reporting Symposium - 2008
Banking Application
Customer• Large subsidiary of a major European bank• Market cap.: ~20Bn• Employees: 50+k
Business objectives• Meet regulatory compliance requirements• Reduce fraud losses, especially internal attacks• Continuous and pre-emptive controls • Expand scope across all business and IT systems• Reduce costs compared to highly manual prior processes
16th World Continuous Auditing and Reporting Symposium - 2008
Banking Application
Technical challenges and requirements• Growth through acquisitions wide variety of disparate IT systems• Data consolidation became a major challenge; multi-terabytes of
historical and real time data such as transaction logs, document files, spreadsheets and financial reports stored on Oracle databases.
• Security administrators were finding it impossible to monitor these vast reservoirs of data in order to detect suspect usage patterns and identify possible fraud before it was too late.
• Non intrusive solution needed to coexist with other IT systems • Independence from other processes to ensure impartial oversight• ‘Events of interest’ are hidden across several system logs and
multiple log entries • Identification of suspicious behavior requires establishing profiles
and patterns (ex. multiple account of the same person)
16th World Continuous Auditing and Reporting Symposium - 2008
• Proactively combating fraud & reducing compliance costs
• D2K Secure reviews 12 -15 Gb per day of data in order to spot suspicious activity before it becomes a problem
• With automatic querying and real time alerts, the bank can now be truly proactive in the fight against fraud
• D2K Secure saves costs every day what previously would take 10 - 15 man days to piece together now takes 3 - 4 hours to run automatically
Banking Application
16th World Continuous Auditing and Reporting Symposium - 2008
D2K Secure – Continuous Monitoring
System Summary
• D2K Secure is a flexible and scalable system designed to transform the contents of an unlimited number of audit log files into a single structured database and perform CM on the aggregate dataset
• Security analysts are provided with relevant information with links back to the original audit trail sources
• With appropriate reporting modules, the system is capable of generating automatic real time alerts if certain usage patterns are recognized in the logs
16th World Continuous Auditing and Reporting Symposium - 2008
D2K SecureSystem
architecture
16th World Continuous Auditing and Reporting Symposium - 2008
D2K Secure – Key Features
• Modular architecture allows integration with other analytical applications
• Combines several complementary methods to provide near 100% matches
• Data may be retrieved from any kind of structured or semi structured source, including but not limited to; web pages, entire web sites, document files, text based log files, any type of relational databases and EDI systems
• The system can monitor multiple data sources and generate digests or reports from collated real-time or buffered information, based on the requirements of the application
• The massively parallel architecture allows simultaneous processing of individual information units, enabling real time processing of virtually unlimited amounts of data with suitable hardware support
16th World Continuous Auditing and Reporting Symposium - 2008
Sample Transactional log
Banking System: Equation1130 line types, 172 transaction
Log parser - XML configuration
Sample (part of the xml file)
Event linking from transactional logs
16th World Continuous Auditing and Reporting Symposium - 2008
Reporting UI example
Monitored events - AML
• 2 years expired between the current and last transaction and the minimum amount is 8k EUR
• High amount transactions in a week• E-bank transactions above 8k EUR• Card transactions above 8k EUR in 2 hours• Data browsing with no transaction• Data browsing within 3 days without transaction• Transaction cancellation above 8k EUR• Transactions of the same customer at the same administrator• Incoming amount over 400 EUR from other bank to worker
account• Incoming >8k EUR to an account opened with <400 EUR• Inquiry last 6 months without transaction• FATF country transactions
16th World Continuous Auditing and Reporting Symposium - 2008
Monitoring events – Dormant Accounts
• Data browsing of dormant account w/ debit transaction last month
• No host branch• Multiple debits in 2 hours, 1 months• Same supervisor access of multiple
dormant accounts• Card initiated requests• Outgoing transfers• Trading in own account with government
securities
16th World Continuous Auditing and Reporting Symposium - 2008
Monitored events
Event type Monitored events
Money Laundering 13
Dormant account 10
Hold m ail 4
E-channels 2
Internet, E-mails 11
CUA 4
Others 12
Summary table
16th World Continuous Auditing and Reporting Symposium -2008
Ad-hoc vs. Continuous Monitoring
Monitoring Ad-hoc Continuous
Setup time / $$ less more
Detection after the fact preventive
Learning/profiling limited technology support captured by CMS config
Latency was 30+ days 1 day
Scaling procedures collapsed w/ growth
15GB / day works fine
Operating costs proportional to data growth & query frequency – Not
able to scale cost effectively
minimal after initial setup
Data structure changes
braked time series analysis consistency
allows consistent time series analysis across
multiple point of changes
Summary
16th World Continuous Auditing and Reporting Symposium - 2008
Thank you for your attention
Andrew [email protected]
m 646-479-4496
Data2knowledge, Inc. www.d2k.com
16th World Continuous Auditing and Reporting Symposium - 2008