SAS Anti-Money Laundering provides a way to assess customer relationships and establish expectations about customer behavior. Part of this assessment involves periodic reviews, and typically, this is risk-based. In this post, I’ll discuss how the next review date for a customer is determined.
When the system scores a customer, it generates an alert if the customer is high-risk. When this happens, the review process starts.
By default, CDD objects that require review are configured with an initial review date indicator, or a Last Review Date, populated when a review is saved. This initial review date is used by the system to calculate a Next Review Date.
It’s important to understand how the Next Review Date is affected as objects are dispositioned or moved through a project workflow.
By default, applying the Retain disposition resets the value of the Next review date. The new Next review date is 90 days from the current date, the date on which the last review was performed. This is a configurable parameter, and your solution administrator might configure a review time of more or less than 90 days for your product deployment.
It’s important to mention that the customer is scored 90 days from the last review or when any of the customer attributes have changed. For example, if the high-risk customer’s score increases more than 10, the alert is reactivated as a high-risk alert.
By default, applying the Change to medium risk or Change to low risk disposition resets the value of the Next Review Date as well. The new Next review date is 90 days from the current date, the date on which the last review was performed. The alert is reactivated unconditionally when the customer is scored again and the score is above high threshold, even if the score has not changed.
In addition, by default, low-risk customers and medium-risk customers are assigned a next review date of a predetermined length based on the initial or last review date. For example, if the customer type is low risk, then the default next review date is three years. If the customer is designated as medium risk, the default next review date is two years.
Please see a summary of the various customer due diligence dispositions and the effects each have on the Nex Review Date:
| Disposition |
Effect on Next Review Date
|
| Retain |
Resets the Next Review Date. The Next Review Date is 90 days from the current date, which is the date of the last review.
Note: This is a configurable parameter. In addition, customers are scored 90 days from their last review date or when any of their attributes change.
|
| Change to low risk |
Resets the Next Review Date. The new Next Review Date is 1095 days from the current date, which is the date of the last review. Even if the score does not change during this time, when the customer is scored again and the score is above the high-risk threshold, the alert reactivates without conditions. |
| Change to medium risk |
Resets the Next Review Date. The new Next Review Date is 730 days from the current date, which is the date of the last review. Even if the score does not change during this time, when the customer is scored again and if the score is above the high-risk threshold, the alert reactivates without conditions. |
| Demarket |
Customer is not re-scored. |
To learn more about the review process and our SAS Anti-Money Laundering solution in general, please visit https://support.sas.com/en/software/sas-anti-money-laundering-support.html.
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