The PostFinance has approximately 3 million customer accounts and uses the risk classification process in the MLDS Money Laundering Detection System to analyze business relationships with private and corporate customers. Individual transactions in risk countries are identified and monitored on an accumulated basis in order to detect any transaction patterns such as smurfing.
The clarification processes relating to ex-ante and ex-post checks are controlled through the electronic workflow of MLDS. The scenarios are mapped into the Innovations rule-based technology Visual Rules, the operating area can define and simulate the rules without requiring IT support. The rule-based technology monitors 3 to 9 million transactions per day, even up to 1 million transactions per minute in peak periods.
Overall responsibility for the process lies with the compliance department, where there is a specialized group that sees to the continuous enhancement of compliance methods and the improvement and supervision of compliance tools. IT is only involved when new parameters for the compliance rules must be introduced, and the IT testing department cooperates on quality control for the rules by testing certain functionalities at release dates.
In addition, the compliance department runs reporting on the scenarios and their execution, which ensures that irregularities are detected. The associate responsible for the Business Rules Management process also support employees in operations in managing the significance and impact of rule scenarios and their proper clarification.