For Money Remitters

compliance rules 400x376Verify and validate that you are following the laws and regulations of countries around the world.  GCS provides the tools to perform data integrity, customer identification, risk analysis, fraud detection, transaction aggregation, and other similar functions in real-time (link analysis and structured transaction detection is partial real-time, partial overnight), so that inappropriate transactions can be flagged at the point of sale.

In addition, GCS uses AI to continuously monitor and risk-score individuals, groups, companies, corridors, agents, and others, to enhance due diligence processes.

Easy Interface to your Current System

GCS uses a simple JSON interface.  Your wire system sends transaction data to GCS and GCS sends back universal customer ID's, aggregation amounts, warning flags, hold flags, etc.  If you want aggregation to be more strict than required by law or regulation, a web-page interface can be used to create custom business rules.  That same web-page can be used to examine customers, agents, aggregation amounts, information about structuring and linking, etc., and even file required CTR and SAR forms (or their equivalents in other countries).

Watch a video tutorial about quickly and easily reviewing and submitting CTRs and SARs.

 

For the Chief Executive Officer

Are you personally protected?

New York State Department of Financial Services is first in the nation to make Chief Executives and Board Members personally liable if your company’s compliance systems are not following all the laws and regulations.

In compliance with these regulations, GCS provides low-cost solutions that help protect agents, companies, and executives from fines, loss of license, and imprisonment.

 

For the Compliance Officer

GCS provides a Transaction Monitoring Program designed for the purpose of monitoring transactions, both during and after their execution, for potential BSA/AML violations and Suspicious Activity Reporting. The program includes the following attributes:

  1. It is based on the Risk Assessment by GCS of the industry, with configuration capabilities to allow customization to the requirements of each individual company using the Program.
  2. GCS reviews and actively updates the Program to take into account and reflect changes to applicable BSA/AML laws, regulations and regulatory warnings, as well as any other relevant information. Furthermore, GCS will work with each individual company to ensure and document that these reviews and updates conform to the individual company’s risk assessment. GCS strives to appropriately match BSA/AML risks to each institution’s businesses, products, services, and customers/counterparties.
  3. The Program uses BSA/AML detection scenarios (implemented in part via business rules, link analysis, and AI risk scoring) with threshold values and amounts designed to detect potential money laundering or other suspicious or illegal activities.
  4. GCS, in conjunction with individual companies, does end‑to‑end, pre- and post‑implementation testing of the Program, including, as relevant, a review of data mapping, transaction coding, detection scenario logic, model validation, data input and Program output; GCS provides appropriate relevant documentation of this testing and these reviews to each customer.
  5. Included with this documentation are the current detection scenarios and the underlying assumptions, parameters, and thresholds that the Program utilizes.
  6. GCS continuously analyzes the relevancy and sufficiency of the detection scenarios, the underlying rules, threshold values, parameters, and assumptions, and as stated earlier, adopts improvements and upgrades on a continuous basis.

The GCS Transaction Monitoring Program includes automated Filtering, for the purpose of interdicting transactions that are prohibited by OFAC and other governmental bodies. This Filtering includes the following attributes:

  1. It is based on the Risk Assessment by GCS of the industry, with configuration capabilities to allow customization to the requirements of each individual company using the program.
  2. It uses industry leading algorithms for matching names and accounts.
  3. GCS, in conjunction with the individual companies, does end‑to‑end, pre- and post‑implementation testing of the Filtering Program. This testing includes i) a review of data matching, ii) an evaluation of whether the OFAC sanctions list and threshold settings map to the risks of the industry and each company in particular, iii) a review of the logic of matching algorithms, iv) a validation of the models used therein, and v) review of the data input and Filtering Program output.
  4. The Filtering Program (along with the Program in general) is subject to on‐going analysis to assess the logic and performance of the Filtering Program. This analysis includes i) a review of data matching, ii) an evaluation of whether the OFAC sanctions list and threshold settings map to the risks of the industry and each company in particular, iii) a review of the logic of matching algorithms, iv) a validation of the models used therein, and v) review of the data input and Filtering Program output.
  5. GCS provides documentation that articulates the intent and design of the Filtering Program algorithms.

The GCS Transaction Monitoring and Filtering Program also performs the following functions:

  1. Automated means for the validation of the integrity, accuracy and quality of data to ensure that accurate and complete data flows through the Transaction Monitoring and Filtering Program (such as address validation, illegal character checking, id number format validation, etc.).
  2. Data extraction and loading processes to ensure a complete and accurate transfer of data from its source to automated monitoring and filtering systems, if automated systems are used.

For the Transaction Monitoring and Filtering Program, GCS provides to each company on an ongoing basis:

  1. Identification of all data sources that contain relevant data.
  2. Documentation (annually) of the qualified personnel at GCS who are responsible for the design, planning, implementation, operation, testing, validation, and on‐going analysis of the Transaction Monitoring and Filtering Program.
  3. An issue tracking system. Whenever GCS or its customers have identified areas, systems, or processes that require material improvement, updating or redesign, these items shall be documented on a tracking system. This tracking system archives and documents GCS’s progress to address such areas, systems or processes. This tracking system is semi-public: all companies using the GCS Program and appropriate auditors and regulators shall have access to this tracking system and can review all such issues.

A web-page interface can be used to create custom business rules that are more strict than the baseline GCS rules. For example, to make aggregation be more strict than required by law or regulation, simply enter a new rule to that effect.

Although it is not a case management system, that same web-page can be used to examine customers, agents, aggregation amounts, information about structuring and linking, etc. Eventually, the web pages will automate the required CTR and SAR form filing (or their equivalents outside the U.S.).

 

For the Chief Information Officer

GCS uses a simple and powerful real-time JSON interface to link with wire systems.

A wire system sends transaction data to GCS and GCS sends back universal customer ID's, aggregation amounts, warning flags, hold flags, etc. Typical latencies from receipt to response are sub-second.

Beyond this basic command, there are many other commands that the JSON interface provides. These commands allow your system to query for relevant records, update agent information, insert new business rules, etc. This interface is indeed the primary means to communicate with the GCS Program (even the Web page interfaces go through it – sometimes dynamically).

We make it easy for you. We maintain the hardware and software. We have redundant sites, spread around the country and the globe.* We perform the required backups. Our servers are housed in well known, well protected data centers. Communications involving PPI use industry standard security protocols. We pay for the required software, databases, rack space, security, etc. You have a single, budgeted expense. And, if you need specialized features, we have the staff to handle your requirements.

The Technology page specifies how we integrate with your wire system.

 * Not all features discussed are currently production ready.  Please see the product road map (under NDA) for anticipated release dates of specific features.

 

For the Chief Financial Officer

Compliance and IT are two of your largest expenses. GCS won’t make them go away, but it will help.

Right now, whenever applicable laws change anywhere in the world your company sends money, your compliance and IT departments usually need to make changes. As CFO, you know the associated costs can rapidly affect the bottom line. And, if some obligations are missed…

With GCS, you won’t have to pay for changes. In most cases, GCS assumes this cost as part of its fees and, essentially, spreads the cost amongst all its customers.

And, because we handle multiple customers, we very quickly become aware of changes, and initiate rapid updates. This industry wide exposure helps mitigate regulatory risk for all our customers.

The Program can be purchased on a per-transaction basis or as a fixed monthly fee (with a not-to-exceed limit on number of transactions).

 

To Get Started

Run a sample of your company’s data through the system for free and without obligation!

GCS web-page tools can generate reports showing all transactions that do not meet the minimum requirements of laws and regulations.  Simply upload a flat-file set of transactions, use the web page to map the data elements from your columns to those used by GCS, and let GCS crunch for a while.

To get started, GCS will set you up with an audit-mode demonstration account.  As a first step, you can access a database with fake data, to play with and examine.  As a second step, under NDA, by yourself or with our help, upload some of your real transactions.  With this, you can evaluate how well your current system will stand up to future scrutiny.  You’ll see what you haven’t been doing properly.  And, how well GCS can detect all the inappropriate transactions.

This review will demonstrate the efficacy of the GCS Program, because, except for being in a sandbox platform, it is the exact same system that will be integrated into yours.

 

How to Deploy

When it comes time to integrate, GCS will provide sample programs, sample interfaces, and technical support (on-site or remotely). Your programmers will need to implement a connection to our JSON interface on your wire system. Many customers have built similar interfaces and this will be a small update.

To ensure a smooth transition to real-time operations, GCS recommends running in parallel for at least a month (preferably longer to cover month-end issues). During this testing phase, your company’s legacy compliance algorithms continue to process and block transactions and we simply compare the results of the legacy and GCS systems. After validating that the timing and interactions work properly, that the business rules appear to be adjusted appropriately, we use the harsher output from the legacy or GCS system.  Finally, when the GCS Program outputs pass all validation tests, and meet or exceed your expectations, you can turn off the old compliance system.