METHOD AND SYSTEM TO EVALUATE ANTI-MONEY LAUNDERING RISK

• US 20050267827A1
• Filed: 09/30/2004
• Published: 12/01/2005
• Est. Priority Date: 05/28/2004
• Status: Active Grant

• Current Assignee: Bank of America Corp.
• Original Assignee: Bank of America Corp.
• Inventors: Grant, Henry W. Jr., Reynolds, Tyler
• Granted Patent: US 8,412,601 B2
• Time in Patent Office: Days
• US Class Current: 705/35
• CPC Class Codes: G06Q 40/00 Finance; Insurance; Tax strategies; Processing of corporate or income taxes
• CPC Class Codes: G06Q 40/08 Insurance

Abstract

A method to evaluate anti-money laundering risk may include identifying a person or other legal entity to be evaluated. A country may be selected associated with the person or other legal entity. At least one financial product or financial instrument associated with the person or other legal entity may be selected. The method may also include selecting a customer type associated with the person or other legal entity. A risk rating may be determined based on responses to predetermined criteria related to the selected country, the at least one selected financial product and the selected customer type.

Claims

1. A method to evaluate anti-money laundering risk, comprising:

calculating a risk rating based on a set of values, each value being assigned to one of a plurality of different possible or selectable responses or answers for each of a multiplicity of criteria or questions associated with a group including at least one of a selected country, a selected financial product or investment, and a selected customer type; and

performing a predetermined function in response to the risk rating.

2. The method of claim 1, further comprising defining the multiplicity of criteria or questions.

3. The method of claim 2, wherein defining the multiplicity of criteria or questions comprises at least one of:

determining whether the selected country is cooperative;

determining if the selected country is on an Office of Foreign Asset Control (OFAC) list;

determining an International Narcotics Strategy Report Rating;

determining if the selected country is a member of the Financial Task Force on Money Laundering (FATF);

determining if the selected country was a party to a 1988 United Nations Convention on drugs;

determining a quality of local laws and regulations;

determining a level of government support related to law enforcement and prosecution of offenders;

determining a strength of the selected country'"'"'s banking industry; and

determining a quality of banking regulation and oversight.

4. The method of claim 2, wherein defining the multiplicity of criteria or questions comprises at least one of:

determining if the selected customer type is currently being monitored;

determining a level of knowledge about the selected customer type; and

determining if the selected customer type is a risk for certain activities.

5. The method of claim 2, wherein defining the multiplicity of criteria or questions comprises at least one of:

determining a level of customer knowledge or sophistication needed to deal in the selected financial product or investment;

determining a level of sophistication or complexity of the selected financial product or investment;

determining the selected product or investment'"'"'s propensity for use in money laundering activity;

determining an ease of access to the selected financial product or investment;

determining the selected financial product or investment'"'"'s attractiveness for use by terrorist.

6. The method of claim 1, wherein calculating the risk rating comprises one of calculating an average of the set of values or a weighted average of the set of values.

7. The method of claim 1, further comprising calculating at least one of a country risk rating, a customer type risk rating, a product risk rating and a relationship risk rating.

8. The method of claim 1, further comprising presenting a graphical user interface for a user to enter at least one of an identification for a legal entity to be evaluated, a country associated with the legal entity to be evaluated, at least one financial product or investment associated with the legal entity to be evaluated, and at least one customer type associated with the legal entity to be evaluated.

9. The method of claim 1, further comprising presenting a graphical user interface to edit the plurality of different possible or selectable responses or answers for each of the multiplicity of criteria or questions and values assigned to each of the plurality of responses or answers.

10. The method of claim 1, further comprising presenting a graphical user interface for a user to select at least one of:

if the selected country is a cooperative jurisdiction;

if the selected country is on an Office of Foreign Asset Control (OFAC) list;

an International Narcotics Strategy Report Rating associated with the selected country;

if the selected country is a member of the Financial Task Force on Money Laundering (FATF);

if the selected country was a party to a 1988 United Nations Convention;

a quality of local laws and regulations associated with the selected country;

a level of government support in the selected country related to enforcement of laws and regulations and prosecution of offenders;

a strength of banking industry associated with the selected country; and

a quality of banking regulation and oversight associated with the selected country.

11. A method to evaluate anti-money laundering risk, comprising:

identifying a person or other legal entity to be evaluated;

selecting a country associated with the person or other legal entity;

selecting at least one financial product or investment associated with the person or other legal entity;

selecting a customer type associated with the person or other legal entity; and

determining a risk rating based on responses to predetermined criteria or question related to the selected country, the at least one selected financial product or investment and the selected customer type.

12. The method of claim 11, wherein determining the risk comprises setting a value corresponding to each of the responses to the predetermined criteria or question.

13. The method of claim 12, wherein determining the risk comprises calculating one of an average or a weighted average of the values based on the selected country, the at least one selected financial product or investment and the selected customer type.

14. The method of claim 11, wherein determining the risk comprises at least one of:

evaluating if the selected country is a cooperative jurisdiction;

determining if the selected country was a party to the 1988 United Nations Convention on drugs;

evaluating a quality of banking regulation and oversight in the selected country;

determining if the selected country is associated with terrorist related activity or on the Office of Foreign Asset Control (OFAC) list;

evaluating a quality of local laws of the selected country;

entering an International Narcotics Strategy Report Rating for the selected country;

evaluating a level of government support in the selected country for enforcement of laws and regulations and prosecution of offenses;

determining if the selected country is a member of Financial Action Task Force on Money Laundering (FATF); and

determining strength of a banking industry in the selected country.

15. The method of claim 11, wherein determining the risk comprises at least one of:

evaluating the person or other legal entity'"'"'s sophistication with respect to the at least one selected financial product or investment;

determining the at least one selected financial product or investment'"'"'s propensity for use for money laundering;

determining the at least one selected financial product or investment'"'"'s attractiveness for use by terrorist;

evaluating a level of complexity of the at least one selected financial product or investment;

determining if the at least one selected financial product or investment is currently monitored for use with respect to illegal activity;

determining a level of the person or other legal entity'"'"'s knowledge of the at least one financial product or investment; and

determining a level of ease of obtaining and using the at least one financial product or investment.

16. The method of claim 11, wherein determining the risk comprises at least one of:

determining if the person or other legal entity is currently being monitored with respect to financial activity;

determining a level of risk of the person or other legal entity being associated with terrorist activity;

evaluating a level of knowledge about the person or other legal entity; and

determining if the person or other legal entity is known to be a high risk.

17. A system to evaluate anti-money laundering risk, comprising:

a server; and

a risk rating tool operable on the server.

18. The system of claim 17, wherein the risk rating tool is adapted to determine a risk rating based on responses to predetermined criteria related to a selected country, at least one selected financial product and a selected customer type.

19. The system of claim 18, further comprising a value being set corresponding to each of the responses to the predetermined criteria.

20. The system of claim 19, wherein the risk rating tool is programmed to calculate one of an average or a weighted average of the values based on the selected country, the at least one selected financial product and the selected customer type.

21. The system of claim 17, wherein the risk rating tool is programmed to determine a risk rating based on responses to predetermined criteria related to a selected country, the predetermined criteria comprising at least one of:

a level of cooperativeness of the selected country with respect to anti-money laundering;

the selected country being a party to the 1988 United Nations Convention;

a quality of banking regulations and oversight in the selected country;

the selected country being associated with terrorist related activity;

the selected country being on an Office of Foreign Asset Control (OFAC) list;

a quality of local laws of the selected country;

an International Narcotics Strategy Report Rating for the selected country;

a level of government support in the selected country for enforcement of laws and regulations and prosecution of offenses;

the selected country being a member of the Financial Action Task Force on Money Laundering (FATF); and

strength of a banking system in the selected country.

22. The system of claim 17, wherein the risk rating tool is programmed to determine a risk rating based on responses to predetermined criteria related to at least one selected financial product or investment, the predetermined criteria comprising:

a customer sophistication with respect to the selected financial product or investment;

a propensity of the selected financial product or investment for use for money laundering;

an attractiveness of the selected financial product or investment for use by terrorist;

a level of complexity of the financial product or investment;

a current monitoring of the financial product or investment for use with respect to illegal activity;

a level of a customer'"'"'s or public'"'"'s knowledge of the financial product or investment; and

a level of ease of obtaining and using the financial product or investment.

23. The system of claim 17, wherein the risk rating tool is programmed to determine a risk rating based on responses to predetermined criteria related to a selected customer type, the predetermined criteria comprising:

a customer currently being monitored with respect to financial activity;

a level of risk of the customer being involved in terrorist activity;

a level of a financial institutions knowledge of its customer; and

the customer being known to be a high risk.

24. The system of claim 17, wherein the risk rating tool is programmed to calculate a risk rating based on a set of values, each value being assigned to one of a plurality of different possible or selectable responses or answers for each of a multiplicity of criteria or questions associated with a group including at least one of a selected country, a selected financial product or investment and a selected customer type.

25. The system of claim 24, further comprising a database including reports used to determine each of the set of values.

26. The system of claim 17, wherein the risk rating tool is programmed to present a graphical user interface for a user to select at least one of:

if the selected country is a cooperative jurisdiction;

if the selected country is on an Office of Foreign Asset Control (OFAC) list;

an International Narcotics Strategy Report Rating associated with the selected country;

if the selected country is a member of the Financial Task Force on Money Laundering (FATF);

if the selected country was a party to a 1988 United Nations Convention;

a quality of local laws and regulations associated with the selected country;

a level of government support related to enforcement of laws and regulations and prosecution of offenses;

a strength of a banking industry associated with the selected country; and

a quality of banking regulation and oversight associated with the selected country.

27. A method for making a system to evaluate anti-money laundering risk, comprising:

providing a server; and

providing a risk rating tool operable on the server.

28. The method of claim 27, further comprising adapting the risk rating tool to determine a risk rating based on responses to predetermined criteria related to a selected country, at least one selected financial product and a selected customer type.

29. The method of claim 27, further comprising adapting the risk rating tool to determine the risk based on responses to predetermined criteria, the predetermined criteria comprising at least one of:

a level of cooperativeness of the selected country with respect to anti-money laundering;

the selected country being a party to the 1988 United Nations Convention;

a quality of banking regulations and oversight in the selected country;

the selected country being associated with terrorist related activity;

the selected country being on an Office of Foreign Asset Control (OFAC) list;

a quality of local laws of the selected country;

an International Narcotics Strategy Report Rating for the selected country;

a level of government support in the selected country for enforcement of laws and regulations and prosecution of offenses;

the selected country being a member of the Financial Action Task Force on Money Laundering (FATF); and

a strength of the banking system in the selected country.

30. A computer-readable medium having computer-executable instructions for performing a method, comprising:

calculating a risk rating based on a set of values, each value being assigned to one of a plurality of different possible or selectable responses or answers for each of a multiplicity of criteria or questions associated with a group including at least one of a selected country, a selected financial product or investment and a selected customer type; and

performing a predetermined function in response to the risk rating.

31. The computer-readable medium having computer executable instructions for performing the method of claim 30, wherein calculating a risk rating comprises one of calculating an average of the set of values or a weighted average of the set of values.

32. The computer-readable medium having computer executable instructions for performing the method of claim 30, further comprising calculating at least one of a country risk rating, a customer type risk rating, a product risk rating and a relationship risk rating.

33. The computer-readable medium having computer executable instructions for performing the method of claim 30, further comprising presenting a graphical user interface for a user to enter at least one of an identification for a legal entity to be evaluated, a country associated with the legal entity to be evaluated, at least one financial product or investment associated with the legal entity to be evaluated, and a customer type associated with the legal entity to be evaluated.

34. The computer-readable medium having computer executable instructions for performing the method of claim 30, further comprising presenting a graphical user interface to edit the plurality of different possible or selectable responses or answers for each of the multiplicity of criteria or questions and values assigned to each of the plurality of responses or answers.

35. The computer-readable medium having computer executable instructions for performing the method of claim 30, wherein determining the risk comprises calculating one of an average or a weighted average of the values based on the selected country, the at least one selected financial product and the selected customer type.

36. The computer-readable medium having computer executable instructions for performing the method of claim 30, further comprising presenting a graphical user interface for a user to select at least one of:

if the selected country is a cooperative jurisdiction;

if the selected country is on an Office of Foreign Asset Control (OFAC) list;

an International Narcotics Strategy Report Rating associated with the selected country;

if the selected country is a member of the Financial Task Force on Money Laundering (FATF);

if the selected country was a party to a 1988 United Nations Convention;

a quality of local laws and regulations associated with the selected country;

a level of government support related to enforcement of laws and regulations and prosecution of offenses;

a strength of a banking industry associated with the selected country; and

a quality of banking regulation and oversight associated with the selected country.