AML Risks and Penny Stocks

For some investors, penny stocks are addictive. The ride is exhilarating: the stocks can provide big returns, or they can crash and burn almost overnight. That volatility is one reason why financial institutions catering to these investors need to have even more stringent security measures in place to eliminate the potential of fraudulent activity.

Penny stocks are easily manipulated. With a very small investment, a buyer can create a temporary uptick in value.  It could be an easy way to launder money – unless the brokerage or institution has strict anti-money laundering (AML) processes in place.

Last week, the Financial Industry Regulatory Authority (FINRA) slapped an $8 million fine on New York-based Brown Brothers Harriman & Co. for its failure to have adequate AML programs in place to monitor and detect suspicious penny stock transactions. There were other infractions as well: failure to submit Suspicious Activity Reports (SARs) in a timely manner, inadequate supervisory systems to prevent illegal distributions of unregistered securities and the overall failure of thoroughly investigating suspicious penny stock activities. In a final coup de grace, FINRA fined the organization’s global AML compliance officer $25,000 and suspended him for nine months.

Proactively installing tighter AML compliance processes makes sense for all financial organizations, but even more so for those facing significantly higher risk on a regular basis. You can learn more about our take on the subject in this article.

by Richard Paxton

Want to learn more?  Alacer’s AML experts will be attending the 19th Annual AML & Financial Crimes Conference, being held March 16-19 at the Westin Diplomat in Hollywood, FL.  Send an email to me at Richard@alacergroup.com to arrange a chat.

AML pushing bank boundaries

There are some interesting findings in KPMG’s Global Anti-Money Laundering Survey 2014 that point to financial institutions making significant changes in response to tighter AML regulations. KPMG surveyed AML and compliance professionals in the top 1,000 global banks in 48 countries, and here are just a few of the interesting factoids that were derived from over 300 responses:

  • regulators are focusing on Know Your Customer (KYC) processes
  • 16% of responding organizations will not be FATCA-compliant by the July 2014 deadline
  • institutions are consistently underestimating the costs of compliance
  • to be successful, banks need an organized and systematic approach to training and recruitment
  • politically exposed personnel (PEP) represent significant risk to their organizations
  • more than half of the respondents never test the effectiveness of their compliance systems after the implementation stage

A whopping 88% of respondents, or nine out of ten, said that AML issues are at the top of their agendas (up from 62% in 2011). And compliance costs are soaring: up on average by 53%.

Not surprisingly, with the number of new regulatory changes, banks are wondering whether or not they can ever achieve a fully compliant AML program. As a result, the organizations are looking to forge stronger ties with regulators, something they were loathe to do 10 years ago. More than 40% said they would welcome a closer relationship with regulators, a big change over the 14% response rate in 2011.

by Richard Paxton

Want to learn more? Alacer’s AML experts will be attending the 19th Annual AML & Financial Crimes Conference, being held March 16-19 at the Westin Diplomat in Hollywood, FL. Send an email to me at Richard@alacergroup.com to arrange a chat.

AML Regs Take On Cryptocurrency

Bitcoin is hot…literally. One of the new wave of virtual currencies that bypass traditional banking systems, Bitcoin is rising in popularity. And it’s not just popular with the average consumer, since organized crime has figured out how to use it to efficiently launder money. For this reason, the U.S. has begun to apply the anti money laundering (AML) rules initially written to govern traditional financial organizations to all digital cash companies.

If you haven’t heard of Bitcoin, you will. Bitcoin experienced massive growth in Q4 2013, and is just one of a number of companies populating a new financial genre: cryptocurrency, or digital encrypted currency. So how does it work? An alternative to cash, Bitcoin is a decentralized, virtual currency that was developed to facilitate all financial activities carried out over the Internet. The currency units consist of a series of numbers that can be traded between accounts, or “wallets,” for services or goods; when it launched in 2009, Bitcoin transactions happened without any government interference (or oversight).

That’s all changing, though, because regulatory agencies such as the Financial Crimes Enforcement Network (FinCEN), the SEC and even the FBI noted that Bitcoin can and is easily being used for a host of illegal activities. Last March, FinCEN issued a ruling that placed cryptocurrency offerings in the same business category as money services – meaning that Bitcoin and its competitors must now follow the same government regulations intended for money transfer companies such as Western Union.

In April 2013, the Department of Homeland Security (DHS) froze the Bitcoin exchange account of Japan-based Mt. Gox – held at Wells Fargo – alleging that it broke AML regulations. In August, almost two dozen Bitcoin payment companies in New York were issued subpoenas in an effort to ensure their AML prevention measures were adequate.

We can expect to see much more in 2014. FinCEN is still evaluating how to best apply AML regulations to cryptocurrency organizations. For now, it is intent on making businesses aware of their reporting responsibilities. But the more the U.S. Government applies regulatory scrutiny to Bitcoin and other cryptocurrency transactions, the more they become legitimized.

(Want to learn more? Alacer’s AML experts will be attending the 19th Annual AML & Financial Crimes Conference, being held March 16-19 at the Westin Diplomat in Hollywood, FL. Send an email to me at Richard@alacergroup.com to arrange a chat.)

by Richard Paxton

Shhh…ACAC is Coming

It’s still under wraps…but we wanted to let you know that we’re putting the final touches on a new corporate initiative: the Alacer Center for Advanced Computing (ACAC).

The term “advanced computing” has many definitions, ranging from supercomputing to quantum analytics. For us, ACAC has three purposes: share, learn and accelerate. It will serve as a showcase for a technology platform that demonstrates the rapidly growing collaboration between Alacer and its partners in the development of big analytics solutions. It will serve as a repository of advanced learning and research in big data, and will be used to share and demonstrate with clients (potential and existing) and colleagues our capabilities in this expanding area of our practice.

ACAC will be led Aaron Hoffer, who recently joined the Alacer team as a senior consultant. Hoffer is a software and data analytics veteran specializing in the usage of big data to design and develop predictive analytics solutions. He comes to us from T-Mobile, where he served as a senior system architect with responsibilities ranging from the enterprise production catalog to the facilitation and integration of new systems and functionalities within the enterprise IT ecosystem.

Within ACAC, Hoffer will work to deliver game-changing solutions in the Internet of Things: how daily lives intersect with social engagement and electronics.

Watch for more information on the Alacer Center for Advanced Computing in the weeks to come.

Alacer Group Adds Financial Industry Veteran Bryan Seale to Anti-Money Laundering and Risk Compliance Consultant Team

Seale augments Alacer’s experience in AML, Six Sigma/LEAN and compliance for financial institutions 

Bellevue, WA – September 9, 2013 – The Alacer Group, dedicated to helping business leaders accelerate performance, quality, productivity and profitability, today announced the addition of Bryan Seale to its financial compliance and Anti-Money Laundering (AML) team.  Seale has more than 12 years of consumer and commercial banking experience in risk management, process improvements, compliance and AML strategies, most recently through his position as leader of the business operations team for Bank of America Corp.

“We’re continuing to see a surge of interest in tightening banking processes in AML, Know Your Customer and other due diligences, particularly as financial compliance officers are hard-pressed to stay current with regulatory changes,” said Richard Paxton, CEO, The Alacer Group.  “Bryan brings strengths in these and many other areas to our team, including a proven ability to drive strategic change through the application of Hoshin Kanri and Kaizen principles.”

During his last 12 years at Bank of America Corp., Seale steered the bank through tremendous changes in its consumer compliance operations.  He defined and managed risk metrics and scorecards, and established controls that mitigated areas of key compliance.  He also served as an AML strategy executive in the commercial bank and global treasury services, where he improved data quality and responsiveness to regulatory agencies.

 

Prior to Bank of America, he was the director of professional services at Spaceworks Inc. and instituted Six Sigma quality programs and productivity initiatives at General Electric Co.  He holds a Master Black Belt in Six Sigma/LEAN processes and earned a Bachelor of Science degree in business administration from the University of Phoenix.

Addressing AML with Alacer:

In many financial institutions, the AML department is struggling due to increased regulatory reviews and the corresponding organizational fines levied for non-compliance.  These factors are catalysts for working with The Alacer Group to address any inefficiencies head on, optimizing processes that enable increased capacity for handling incremental volume without materially increasing expenses.

About The Alacer Group:

Headquartered in Bellevue, WA, with offices in New York and Dallas, The Alacer Group is a business consulting firm focused on four practice areas: big data, technology, finance and healthcare. Offering expert consultants around the globe, Alacer works with companies to resolve their needs quickly and smartly, resulting in positive outcomes.  For more information, please visit the website at www.alacergroup.com or find us on LinkedIn.

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Media Contact:

Rachel Berry

VOXUS, Inc.

253-444-5441

rberry@voxuspr.com

Machine Learning and Big Data

At Alacer, we’re interested in all facets of big data.  Lately, we’ve been fascinated by the broader tech community’s increasing chatter about machine learning.  It’s certainly a hot topic: enterprise personnel who previously yawned widely when they heard the words predictive analytics suddenly are intrigued by how a computer might become more intelligent over time and help solve business-related issues such as financial fraud and security.

The reality is, predictive analytics and machine learning are, in many ways, the same concept.  Machine learning centers around building computer programs that automatically improve a computer’s performance through experience.  Examples might include speech recognition systems that become more accurate over time based on the frequency of the computer’s interaction with the user, or a bank system’s analysis of potential fraudulent use patterns that can eventually differentiate between thieves and good customers.

Some analysts believe that machine learning technologies already outperform traditional analytics – the key is how a computer independently recognizes repetitive patterns and outcomes across a much wider dataset than what traditional data collection techniques can generate.

Fortune 100 companies such as Google and Amazon routinely utilize machine learning to help exploit data collection methodologies.  In fact, Amazon is heavily recruiting for machine learning scientists to join its teams in Seattle, Berlin and Bangalore.  The ML team develops algorithms that model patterns within data to drive automated decisions in ecommerce, web services and digital media.

So where are we heading?  Earlier this year, Microsoft sponsored a summit that assembled key researchers to talk about the dawning era of machine learning and the exciting developments that are causing scientists to believe that some of the greatest computer science-related problems may be solved in the very near future.  As an example, quantum computers with machine learning could dramatically speed up tasks that have previously eluded scientists – such as mapping the universe.

Big data and machine learning are facilitating a brave new world…what’s your take on the topic?

Mobile Telco Churn Infographic

Alacer-Mobile-Telco-Churn-970x1487

Recently, Ed Sarausad wrote an article for RCR Wireless that discussed how big data could be used to develop a plan to counter customer churn in the wireless industry.  We thought it might be interesting to create an infographic that would more clearly illustrate this growing problem: what causes a customer to leave a service provider, how quickly a customer tends to leave any given carrier and how costly high turnover can be for a company.

Reality Check: Using Profitability to Determine Churn Strategies

The American mobile telecommunications industry has matured from its early days of explosive growth to a saturated and fiercely competitive market where carriers are battling to simply retain existing customers. The industry now has one of the highest customer churn rates in business; as an example, in August 2012, T-Mobile US’ churn rate was 2.1%, which may seem miniscule until you factor in its millions of subscribers. In fact, voluntary customer churn has become so pervasive that many companies are redirecting vast sums of their marketing dollars from developing customer acquisition programs to devising churn management strategies. Gartner recently reported that marketing budgets for customer retention will increase by more than 50% by 2015.

Most often, service providers are reactionary in their efforts to address voluntary churn. But what if unstructured data could be used to develop a model that could identify the most lucrative customers and help develop a proactive program for ensuring their loyalty?

At the end of the day, the goal for any voluntary churn reduction program is revenue stabilization and augmentation. Given that, looking at a subscriber’s profitability is arguably a better model for developing a targeted marketing program than utilizing overall subscription numbers as a benchmark. Not all subscribers are equal in value; in fact, based on cost versus profitability, there are some customers that it might be wiser for a service provider to proactively lose from a revenue standpoint.

The Alacer Group tested this theory in a recent project for a U.S.-based tier-one service provider. By mining unstructured historical data to understand and track the variables that caused its customers to leave, we developed a model that could identify the most profitable customers vulnerable to future churning. Data was extracted from activity areas such as customer billing, network access and call detail records. We could then predict the level and likelihood of voluntary customer churn – giving the carrier a proactive roadmap for countering it to help maintain profitability.

The objective was to sift through enough data to develop a plan to proactively reach out to subscribers before they terminated their contracts. In taking a profit-centric approach to the task, we developed a profit-churn score for each customer by examining more than 70 different pieces of information on more than 70,000 subscribers. Through a binary logistic regression, we could predict with a 60% accuracy rate whether or not any given subscriber would churn. Each customer was then assigned to four different quadrants within a matrix that described the nature of the customer and helped determine actions to be taken for desired outcomes.

And this is where it got interesting: we learned that 35% of the carrier’s subscribers were more profitable than the average customer, and that they generated a whopping 61% of the carrier’s cumulative expected profit per month.

To identify these highly profitable subscribers, each received a combined score to assign them to a specific quadrant. For example, a customer with a profitability score of 7 and a churn score of 5 received a combined score of 75. Each two-digit score could then be read like a set of X,Y coordinates. The boundaries of the quadrants were created from carrier data set at break points driven by business needs. The churn axis breaks between 2 and 3 where there is a 50% or more probability of churning. The profitability axis breaks between 3 and 4 where the mean profitability was calculated.

By putting the churn and profitability models together, we end up with a useful framework for informed marketing actions. The profitability of each customer can be used to prioritize those who should receive immediate attention, and identify the high cost/low return customers where churn might actually be desirable. The carrier can now develop retention plans focused on its most highly profitable customers who are likely to churn; unprofitable customers are either allowed to leave or targeted for movement to a more profitable status.

The model identified several churn predictors and potential strategies that could be used to retain the carrier’s most valued customers. Examples include:

–Customer service calls. In this instance, the customer has contacted the customer service team. Through an integrated CRM program, the team can indicate that this customer is a retention priority. The profitable customers who are likely to churn would be at the top of the work queues for callbacks.

–Higher unique subscribers. This would indicate that the customer does a lot of business with the carrier and will regularly shop for volume discounts. The carrier could proactively discount additional lines and offer to consolidate any lines the customer has across multiple carriers.

–Children in household. The carrier could offer discounted family plans to encourage others in the household to join the existing plan instead of choosing a competing offer.

–High credit rating. These are customers who can easily take business elsewhere since they are not locked into a plan due to poor credit. For these customers, the carrier can proactively offer early discounts to extend a 24-month commitment.

A quantitative approach to combining churn and profitability models helped this carrier develop voluntary churn counter measures that effectively moved it from a reactive stance to a proactive one. It’s just one example of how big data can provide marketers with a more useful framework for developing proactive action plans that positively affect the bottom line.

Reality Check: Using profitability to determine churn strategies by Ed Sarausad
RCRWireless, June 11, 2013

 

 







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