PrintYou will work individually on the AML/CTF Case Study in Lessons 5 & 6. However, you may collaborate, discuss, ask & answer questions in the Discussion Forums for both lessons.
Case Study: Location Intelligence to Support AML/CTF Investigations,
Part 1 - Placement and Layering
1. This is a case study to expand your understanding of location intelligence, AML/CTF investigations, chosing and applying various geospatial analysis methods to detect anomalies and patterns, and making recommendations on the next steps of the AML/CTF investigation.
a. Follow the financial trail of a hypothetical, fictional college student over 18 months of his freshman year, summer, and sophomore year. The story starts that multiple suspicious activity reports (SARs) have been filed on this person of interest. The initial SAR was filed by a local bank, second SAR used his Dad's name and the report was dismissed, and the third was serious to include international wire transfers.
b. Blake Glover (fictional character) began freshman year as a resident college student, started making money with a summer job, and opened a credit card. Then, he deposited more money, transferred funds around, and the financial trail gets more complicated.
c. How does one use GIS in AML/CTF investigations? What does an investigator look for in AML/CTF? e.g. what patterns do they look for, why care about an individual's banking practices?
2. Multiple SARs have converged on a suspicion of money laundering and possible illicit activity with Blake Glover. The investigation team "reads you in" on the situation to produce location intelligence to support the AML/CTF investigation. SARs are highly confidential and we can't release the specifics of the initial SAR, submitted when a FI clerk expressed concern over repeat transactions at their State College branch.
a. Look at repeat deposits with an eye toward space and time; location and frequency of deposits.
b. A summary of the SAR circumstance on Blake Gover is available through Canvas, Lesson 5.4.
c. In response to the inquiry, banks produced transaction reports for you to start a geospatial analysis, e.g. credit card transactions, new bank transactions, information regarding multiple cash deposits.
d. Integral to BSA compliance is for a Financial Institution (FI) to Know Your Customer (KYC):
-
What do you know about the [your] customer of interest?
-
What financial services are/were provided to this customer?
-
What do you want to find out?
-
What do you request? Other reports can be pulled.
3. As the geospatial analyst assigned to develop location intelligence in support of this AML/CTF investigation, you now have access to transaction reports, credit card statements, and an awareness of casino transaction report (CTR) and SAR.
a. Review the structured and unstructured datases. Organize the data to identify normal, consistent transactions; anomalies; and financial patterns suggestive of money laundering.
b. Select and use analysis tool(s) to demonstrate your ability to analyze geospatial data, categorize and quantify financial data, and visualize patterns. In a descriptive analysis, produce insights into the past - Blake Glover's activities tied to the SARs and AML/CTF investigation.
c. Examine the financial and geospatial information to identify and categorize, if applicable, transactions and patterns of the first two elements of money laundering (placement and layering).
d. Provide location intelligence and feedback to stakeholders. What to do with results of analysis? Map, visualize, chart to depict patterns, relationships, situational awareness with an executive summary. Consider your busy investigative team; keep your slides informative, visual, and brief.
Case Study: Step 1 - Placement
- Review Placement, what do you note about the transactions?
- What patterns emerge from your analysis of the student's financial transactions, purchases, deposits, or geographic connections?
Case Study: Step 2 - Layering
- Review Layering, what do you learn from the transaction reports and activity?
- Do the student's behaviors or financial trail suggest a flow of illicit funds or corridor(s)?
Deliverable:
Complete the Money Laundering Placement and Layering activity; submit an Initial Presentation of your analysis (sequence of slides/images/maps/reports with your comments annotating the presentation) and an Initial Written Report (about 2 pages, Word document).
1) Create a Powerpoint Presentation of your Transaction Analysis. Approximately five slides will cover the concepts of Placement & Layering. Please include the following in your PowerPoint Presentation and post it in the Lesson 5.4 Activity Case Study: Location Intelligence for AML/CTF Investigations, Steps 1 and 2 drop box. Any cover page slides or reference slides do not count towards a suggested number of slides in a presentation.
- Maps or other visualizations of the investigation area of interest, locations where money was placed (initial step of laundering) area with any relevant polygon and point layers visible and symbolized.
- Financial & geospatial information which evidence the results of your analysis and address the elements of Placement and Layering. NOTE: You may wish to clip the report to highlight elements you wish to be clearly visible in your presentation.
- Brief explanation/rationale for your suggestions as commentary to your images.
2) As your Individual work, write a 2-page Report summarizing your findings of Placement and Layering.
- Support or refute that Glover's financial actiivity and behaviors suggest Money Laundering. What patterns of Placement and Layering do you identify?
- Include maps, figures, charts, or graphs to support your findings and argument. These may be from the transaction analysis or visualizations of the data which you create.
Your grade will be based how well you make your case both in terms of evidence and presentation.
Due Tuesday 11:59 pm (Eastern Time)