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Issue Based - Typology Driven Investigations
Issue Based - Typology Driven Investigations
Phillip A. DeLuca
JPMorgan Chase & Co
Mid-Atlantic AML Conference
July 2011
Monitoring and Investigations
Our strategy is to continue to enhance our ability to identify illicit activity with greater
h llenges as an ind
One off our chall t iis eli
dustry liminati
i tion off noiise and
d theid
identificati
tifi tion off ttrue money
laundering and terrorist financing risk. At JPMorgan Chase we incorporate Money
Laundering/Terrorist Financing typologies identified from previous investigations into our
investigative approach, and create a risk models encompassing, product, geography, and
customer type.
type The models help to provide a detailed road map for investigators to
conduct their investigations. This approach also allows more precision in building
sustainable monitoring tools to identify suspicious activity and provides the investigator
with a more purpose through which to conduct investigations. We term this “finding a
needle in a world of haystacks
haystacks”..
We’ve applied this approach to several areas like Human Trafficking, Black Market Peso,
Continually focus on higher ML/TF risk at all stages of monitoring and investigations within any given population
(Portfolio)
Severity of
Likelihood
of ML/TF
consequence ML/TF
activity
s if ML/TF
activity Risk
“AID” the investigator in making effective and efficient ML/TF risk decisions:
Automated idata gathering
Infformatiion enrichhment
Customer $730,000
of cashed checks,, mostlyy
round dollar and all under
$10K
Medicare
$838,656 $50,869
EMS Company #1 for
2004 Bentley Cont GT
$50,000
wire to
BANK in NIGERIA
Medicare
$392,000
EMS Company #2 $110,000
In cashed checks
$140,000
In official checks or
wires to other
individuals
individuals
Customer $343,000
of checks or wires to other
US banks (no apparent nexus
to COGS)
Medicare
$1,015,138 $261,334
EMS Company #3 accumulated balances
as of 12/31/2010
$567,000
$197,000
In round dollar wires
to
Individual in Nigeria
Healthcare Fraud example #3
Customer
Medicare
$1 MM
Health Care
company
$840,000
$840 000
Consumer Account In round dollar
wires to
Individual in
Nigeria
Human Trafficking Investigation
Purpose and time period: Literature review conducted pursuant to the Human Trafficking project
revealed that low-priced illegal prostitution services, such as those advertised on Craigslist and other
internet classified advertisement-type services, are a high risk for human trafficking and juvenile sex
trafficking JPMC conducted an issue
trafficking. issue-based
-based investigation to determine if Chase retail accounts were
being used to facilitate sexual commerce. The review looked at customers with extensive payments to
Craigslist occurring in May 2010.
geography
— JPMC is in the process of building monitoring strategies based on the typology review to continue
to detect customers possibly associated with trafficking
Human Trafficking Example #1