As discussed in previous blogs in this series, banks and other financial services firms have built large-scale, complex operations to comply with regulations addressing money laundering and other financial crimes.  Leading banks are now leveraging innovation and emerging technologies to create value and increase the effectiveness of anti-money laundering (AML), know your customer (KYC) and other processes related to financial crime prevention.   

The integration of surveillance functions presents an important opportunity to potentially help reduce costs and increase effectiveness in financial crime prevention.  Currently, surveillance functions are rarely integrated, and surveillance data gathered by one team is rarely shared with other teams, even though sharing can provide both preventative and post-event investigative capabilities to help mitigate future risk.    

Banks engage in different types of surveillance, including trade surveillance (with banks setting trade limits and reviewing breaches as they occur) and communications surveillance.  Profit and loss review and other control functions – as well as other compliance, back office and middle office reconciliation activities – help prevent abuse or illegal conduct.  But these surveillance functions are often disparate and disconnected, conducted desk by desk or business by business.   

Separate surveillance functions include: 

  • Market – monitoring trading and trading functions to prevent illicit trading activities 
  • Employee – monitoring employee emails, personal trades and, in certain cases, phone calls 
  • Social media – tracking employees use of social media, both inside and, in some cases, outside the organization 
  • Financial crime – AML, anti-bribery and corruption and actions in contravention of sanctions 

Surveillance is currently a reactive process using tools that look at past patterns to determine if a breach has occurred.  However, a surveillance model that integrates functions; that uses data as needed, rather than from specific silos; and is proactive, rather than reactive, can find broader patterns in areas including financial crime, cyber security, conduct risk, and third-party vendors as well in traditional surveillance functions.    

An integrated model combines real-time and proactive surveillance of employee, firm and client activities with analytics to identify patterns of individual tendencies and collective behaviors.  When run by the right people in the right location, such a model can generate significant returns, not only in terms of preventing and reducing adverse events, but in demonstrating to regulators, shareholders, customers, business partners and employees the bank’s commitment to be a stable business partner.  

We have explored in this series how new approaches and innovative technologies are changing the way financial institutions derive value from their activities aimed at preventing, detecting and mitigating financial crime.  For more information, click on the links below or contact me at 


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