Global Financial Crimes Compliance · 2013 – 2016
JPMorgan Chase & Co. — J.P. Morgan Asset Management
- Compliance analytics and client screening2013 – 2016
- Sanctions (OFAC) screening
- Customer due diligence
- Compliance analytics and reporting
Loop 1 · Build the reporting
Loop 2 · The flywheel
Every day, more than 200 million client and customer records were screened against government watchlists. Records from a bank assembled through decades of acquisitions, often thin outside the US, met lists that can give little more than a name and a birth year. The result was thousands of possible matches a day.
Each possible match is a case. An analyst has to prove, with evidence, that the customer is not the person on the list, or escalate. A list entry with a birth year and a customer born on 1 January (a common placeholder when only the year is known) prove almost nothing.
I started out working this queue, in a new operations team that grew from 30 to 120 screeners. Nobody could see throughput per analyst, or how long any alert had been open, and an alert left to age is a regulatory finding. I built that reporting from the screening tool’s PDF exports in VBA, and turned it into the daily, weekly and monthly reporting that went to senior management and to regulators.
Then the reporting became a flywheel. Escalations that came back as false positives, and samples of closed alerts, showed where each analyst needed help, so training could be targeted. The same patterns went to engineering as screening-rule and data fixes, so fewer false positives reached the queue. The team got faster and more consistent as it grew, the flywheel working in tandem with that growth. I led 12 analysts while running the reporting for the whole organisation, by then 120 screeners, 7 to 10 team leads and 3 data analysts, and then moved to data full time, reporting to the VP of Operations. Sitting between the business and its engineers is where I learned product management.
Illustrative: invented records, scores and figures. Watchlists are public record, e.g. OFAC, 1 June 2001 ↗
