Technology and Systems Reviews

The Data Analytics team is often a “consumer” of system data or alert outputs generated by our clients, wherein that information is needed to respond to a regulatory investigation. As a result of our visibility into the technology architecture in place at many financial firms, the Bates team can provide insight and guidance into the accuracy, efficiency, and completeness of programmatic processes relied on by our clients. These reviews evaluate the flow of information throughout the firm, and where needed, Bates can provide consultative guidance on modified processes, new technology implementation, or provide custom fixes and improvements to existing programs.

Bates also provides tuning and verification services for specific alert or surveillance functions, such as evaluating AML thresholds in place, or product/activity specific trade alerts. 

We focus on three primary review points to do this:

• How are the Alerts described on paper, or understood by supervisory personnel?
• How are the Alerts implemented in practice within the firm’s monitoring systems?
• How do the Alerts compare to industry best practices, and are there ways to improve its accuracy?

After establishing an understanding of how Alerts are intended to work (through discussion with internal personnel and review of written policy), we replicate the Alert in our own programmatic environment, allowing us to run a large quantity of recent trade data through the replicated system. Comparing the activity that triggered the Alerts in the replicated environment to the Alerts that were triggered internally allows us to identify potential gaps in the way the Alerts are implemented at the firm and how they are understood and described to be functioning. Beyond identifying gaps, Bates can also provide suggestions on whether and how Alert parameters can be refined to generate “better” Alerts (i.e., fewer false positives) in addition to providing perspective on how Alert parameters compare to those of relevant peer firms. Where needed, the technology team will bring in subject matter experts from Bates’ broad range of expertise to provide our clients with the best possible advice.