A JFSC regulator's view of Customer Risk assessments (CRAs)

The Comsure team and its iTrack customers were pleased to benchmark iTrack against regulatory expectations.

iTrack is a unique cloud-based CRA system used by supervised forms in Jersey, Guernsey, and Mauritius. 

• itrackaml.com/iTrackPromo.mp4

I have included below more details about iTrack, along with the JFSC's assessment of CRAs in Jersey.

JFSC CRA ASSESSMENT

The JFSC reviewed Jersey-supervised firm's CRAs in 2022, and a key observation was:-

• Nearly half of the participants used a spreadsheet solution, with roughly a third using a systems-based methodology and the remainder recording risk assessments manually (e.g. paper-based).

Their report is here.

• https://www.jerseyfsc.org/industry/examinations/fp-thematic-examination-customer-risk-assessments-2021/
• https://www.jerseyfsc.org/news-and-events/video-update-customer-risk-assessments-cra-thematic-examination/

The regulators also walked the industry through the report through a video [links below] -

• https://vimeo.com/696470592 - (it starts on about 4 minutes and goes on to 26 mins)

To produce the information above, the JFSC sent all respondents a CRA questionnaire

• See here http://jerseyfsc.org/media/5220/cra-questionnaire-2021.pdf -
• These questions offer some thoughts about what would be expected in a CRA

CONCERNING THE ABOVE, COMSURE HAS A SOLUTION THAT MEETS ALL THE NEEDS OF THE JFSC

iTrack  

Based on a methodology designed by public and private sector AML/CTF/CPF experts and mapped against local and international standards, Comsure's Risk Assessment tool (iTrack) is a web-based solution that delivers a comprehensive, automated risk-based reportable profile of an institution's products, services, geographies, and customer entities through a flexible and scalable platform for institutions of all sizes.

• iTrack promo video – https://itrackaml.com/iTrackPromo.mp4

Comsure's Risk Assessment is a trusted, standardised means of measuring, understanding, and explaining an institution's financial crime risks.

1. Establishing AML/CTF/CPF standards based on global best practices and the latest guidance and regulation from authoritative sources worldwide
2. Providing Automation which aggregates multiple risk categories and provides seamless updates to address any regulatory changes
3. Utilising qualitative and quantitative data features which score risk and offer a comprehensive FINANCIAL CRIME risk profile
4. Creating presentation-ready reports, charts and tables, allowing you to communicate your risk to stakeholders, including regulators, while eliminating the need for cumbersome manual reporting
5. Benchmarking and comparative reporting, providing a framework for future AML/CTF/CPF standards. Further to the above, you can also verify your risks

Comsure has developed a simple yet effective online risk measurement tool, currently known as “iTrackAML”. Along with local requirements (JFSC, GFSC, MFSC, SFSA etc.) ITrack meets the standards required by international regulatory bodies and international standard setters such as:

• Wolfsberg methodology guidance – click here 
• https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsberg-standards/15.%20Wolfsberg_RBA_Guidance_%282006%29.pdf
• FATF (click here for FATF guidance) –
• https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/High%20Level%20Principles%20and%20Procedures.pdf.coredownload.inline.pdf

ITrack provides a bulletproof system to allow firms to demonstrate to “Regulators” the robustness of their AML/CTF/CPF systems, including:

1. Client Take On,
2. Verification[*],
3. Risk Assessments,
4. Monitoring,
5. Management reporting (e.g. Pie/Bar summary graphs)
6. Reporting (Inc. Suspicious Activity Reports [SARs] and
7. Record-Keeping (and GDPR data management)

*As an enhancement to the core functionality of iTrackRisk, Comsure can also offer ITrackSanctions - ITrackSanctions offers data screening through APIs into Sanction data (OFAC, UN, EU*) and Politically Exposed Person [PEP] [and other high-risk information] and Adverse Media data through a dedicated matching engine and Data suppliers such as

These data sets can be matched individually or in batches and every night for continuous monitoring

For further information and to see at a glance the core functionality of iTrackRisk, CONTACT MATHEW@COMSUREGROUP.COM or click here: https://www.comsuregroup.com/media/1336/itrack-booklet.pdf

SOURCE - https://www.comsuregroup.com/advisory-product-support/itrack-AML/CTF/CPF/   

Other sources

• https://www.comsuregroup.com/news/comsure-s-itrack-client-risk-assessment-cra-used-by-tcbs-investment-businesses-estate-agents-accountants-and-others/
• https://www.comsuregroup.com/news/ask-mat-how-does-a-customer-risk-assessment-cra-determine-whether-my-customer-is-involved-in-illicit-activities-such-as-money-laundering/