Anti-Money Laundering patent review

I was recently reviewing some anti-money laundering (AML) patents to see if any had been published recently (published does not mean granted).

Here’s a few links to some patents, some granted some applied for:

All of the patents describe a general purpose system of calculating a risk score. The risk score is based on several factors.

In AML, the key data include:

  • A legal entity (name, location, type)
  • A “location” (typically country) that determines the set of rules and “data lists”  to be applied. This could be the LE’s country or it could be the financial instrument’s country but generally this embodies a jurisdiction area that applies to the AML effort. A “data list” from a country or location is the list of legal entities that are being watched or have been determined to engage in AML operations. So we have a mix of suspected and validated data.
  • A financial instrument / product and its set of attributes such as transactions, amounts, etc.
  • A jurisdiction: the risk assessor’s set of rules. Typically these are rules created by a company or a line of business. These rules help identify an event and should be relatively consistent across an entire enterprise but also vary based on the set of locations where a company may operate. A bank’s Compliance Officer is especially concerned about this area as it also contains policies. The policies represent who needs to do what in which situation.

I have not tried to capture the nature of time in the above list since all of these components can change over time. Likewise, I did not try to capture all of the functions a AML system must perform such as regulatory reporting. We have also ignored whether all of these components are used in batch or real-time to perform a function. Or whether rules engines and workflow are powering some incredibly wonderful AML “cockpit” for an AML analyst at a company.

We assume that the ultimate goal of a AML system is to identify LE’s potentially engaging in AML activities. I write “potentially” because you need to report “suspicious” activities to the Financial Crimes Enforcement Network (FinCEN). We can never know for certain whether all of the data is accurate or that an individual transaction is actually fraudulent. We can, however, use rules, either a-priori or predictive, to identify potential AML events.

The patents describe a method of combining information, using a “computer system” to calculate a AML risk score. The higher the score, the more probable that an LE-FinancialProduct is being used for money laundering. Inherently, this is probabilistic. It’s also no different than any other risk scoring system. You have a bunch of inputs, there is formula or a predictive model, there is an output score. If something scores above a threshold, you do take action, such as report it to the government. Just as a note, there are also strict guidelines about what needs to be reported to the government as well as areas where there is latitude.

The trick in such a system is to minimize false positives–LE-FinancialProduct combinations  identified as money laundering but in reality are not. False positives waste time. So the system tries to create the best possible discrimination.

So now look at the patents using the background I just laid out. They are fairly broad, they described this basic analysis workflow. It’s the same workflow, using the same concepts as credit scoring for FICA scores, or credit scoring for many types of loans, or marketing scoring for lifetime value or next logical product purchasing. In other words, the approach is the same. Okay, these are like many existing patents out there. My reaction is the same: I am incredulous that general patents are issued like they are.

If you look past whether patents are being granted for general concepts, I think it is useful to note that many of these came out around 2005-2006 or so which is a few years after many regulations changed with the Patriot Act and other changes in financial regulations.

So the key thought is yes, patents are being submitted in this area but I think the relatively low number of patent applications in this area reflects that the general workflow is, well, pretty general. Alright, the 2011 patent has some cool “graph/link analysis” but that type of analysis is also a bit 1980s.

Note: I selected a few data concepts from the real-time AML risk scoring patent to give you a feel for the type of data used in AML around the transaction:

  • transaction amount,
  • source of funds such as bank or credit cards,
  • channel used for loading funds such as POS or ATM,
  • velocity such as count and amount sent in the past x days,
  • location information such as number of pre-paid cards purchased from the same zip code, same country, same IP address within x hours,
  • external data sources (.e.g. Interpol List) or internal data source
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