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Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc. www.d2k.com 16th World Continuous Auditing and Reporting Symposium Rutgers University, NJ; November 2008

Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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Page 1: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 2: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

Presentation outline

• About Data2Knowledge

• Continuous Monitoring Needs

• Banking Application

• D2K Secure, Continuous Monitoring System

16th World Continuous Auditing and Reporting Symposium - 2008

Page 3: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 4: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 5: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 6: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 7: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 8: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

• 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

Page 9: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 10: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

D2K SecureSystem

architecture

16th World Continuous Auditing and Reporting Symposium - 2008

Page 11: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 12: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

Sample Transactional log

Banking System: Equation1130 line types, 172 transaction

Page 13: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

Log parser - XML configuration

Sample (part of the xml file)

Page 14: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

Event linking from transactional logs

16th World Continuous Auditing and Reporting Symposium - 2008

Page 15: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

Reporting UI example

Page 16: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 17: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 18: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 19: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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

Page 20: Continuous Monitoring & Reporting Compliance & Fraud Monitoring Banking Sector Data2knowledge Inc. Andrew Gonczi, CEO Data2knowledge, Inc

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