Enhanced Due Diligence with iceDQ for FinCEN

Case Study

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Enhanced Due Diligence with iceDQ for FinCEN

Figure 1

Customer credit ratings are crucial for assessing commercial and money laundering risks associated with both commercial and individual loans. To address these concerns, the Federal Financial Institutions Examination Council (FFIEC) and the Financial Crimes Enforcement Network (FinCEN) have provided guidelines for Anti-Money Laundering (AML) and Enhanced Due Diligence (EDD).

EDD necessitates the validation of customer data attributes before Enterprise Credit Risk Rating (ECRR) is calculated, which serves as a key indicator for risk and compliance officers in making loan approval decisions.

Streamlining the EDD Process: Recognizing the limitations of manual processes, which are costly, error-prone, and often fall short of regulatory requirements, the bank adopted iceDQ’s automated Data Reliability Platform in 2024.

Benefits of iceDQ: iceDQ enabled automated daily checks on 12,000 accounts data. iceDQ not only helped the bank meet regulatory requirements but also improved productivity by reducing the time and cost associated with manual data validation.

The EDD Attributes

EDD is a crucial component of a sound risk management framework for financial institutions. It involves a comprehensive assessment of various ECRR attributes to determine the creditworthiness of a customer.

Figure 2

iceDQ evaluated a range of ECRR attributes such as:

  • 1. Mailing Address
  • 2. Legal Address
  • 3. Funding Source
  • 4. Transaction Value
  • 5. Expected Activity
  • 6. Transaction Count
  • 7. Country of Residence
  • 8. Citizenship
  • 9. Account Purpose
  • 10. Occupation
  • 11. Nature of Business

Understanding the Data Workflow

Below figure 3 highlights the data flow of the entire due diligence process.

Figure 3

Workflow 1: Booking Process

  • EDD data points are captured by multiple systems in a DB2 staging area via delimited files.
  • Multiple transformation logic takes place here to standardize the data and send it to a Party table.
  • All the standardized data is consolidated in the Party table.
  • Consolidated information flows to a standardized feed, then to the data lake.
  • Data is transferred to the ECRR system for risk rating calculation.
  • Risk rating is stored with the customer profile.
  • Red flags are raised for issues with customer profiles or information.

Workflow 2: Post-Booking Process

  • Changes in customer information (e.g., address, name) trigger this process.
  • Updated information is processed, and risk ratings are recalculated.
  • Red flags are raised if issues are detected with the risk rating.

Testing and Monitoring with iceDQ

The financial services firm implemented iceDQ to automate and enhance their data validation and reconciliation processes. Refer figure 4 to see how at each stage iceDQ monitored data for accuracy.

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Figure 4

iceDQ’s data validation & reconciliation testing scope:

A. Delimited Files vs DB2
B. Transformation validation and reconciliation for DB2 vs DB2
C. Downstream reconciliation DB2 vs Hadoop Data Lake
D. Continuous monitoring of customer activity through the ECRR System
E. Business validation of customer additional information

iceDQ Platform Rule & UDF Overview

Refer to figure 5 below, which shows an iceDQ reconciliation rule connecting the staging area (DB2) as the source and the Party (DB2).

Figure 5

– In section A, the staging area DB2 database is selected as source.
– In section B, the Party DB2 is selected as target.
– The column, key_acct is chosen as the diffjoin type.
– In section C, the result type is set to “A-B” and “B-A”. This checks if all the records in both source and target are exact replicas of each other.

The above section covers reconciliation testing in iceDQ. Now, let’s explore how iceDQ validates transformation logic using a user-defined function (UDF) and incorporates all the rules into a regression suite for continuous data monitoring on predefined schedules. Refer to figures 6 and 7 below for details.

Figure 6

Figure 6 above shows a custom UDF created in iceDQ to check transformations:

  • Each account can have funds from salary, investments, and stocks.
  • These are stored as three separate entries in the database.
  • The values for these sources change over time.
  • Each source has a unique code.
  • Aggregate all rows based on the account ID.
  • Apply conversion logic after aggregation.

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Figure 7

Figure 7 above shows a regression suite in iceDQ:

  • All the rules are integrated into regression suites and executed in a specific sequence according to a predefined schedule.
  • This automated process ensures continuous monitoring and validation of data.

Key Benefits of iceDQ

  • Regulatory Compliance: Improved data quality and traceability supported compliance
    with financial regulations.
  • Automated Transformation Logic Checks: User-Defined Functions (UDFs) control all
    transformation logic checks.
  • High Volume Processing: The system handles the processing of more than 12,000 new
    accounts and account updates daily.
  • 100% Automation: The entire process is fully automated, reducing manual intervention
    and potential errors.

Conclusion

By leveraging iceDQ’s capabilities, the global financial services firm successfully automated and enhanced its Enhanced Due Diligence process. This implementation not only improved data accuracy and efficiency but also strengthened the firm’s risk assessment and regulatory compliance posture. The success of this project demonstrates the critical role of automated data testing in modern financial operations, particularly in high-stakes processes like customer due diligence and credit risk assessment.

About iceDQ

iceDQ empowers organizations to ensure data trust and reliability throughout the data life cycle.

Our comprehensive platform combines data testing, data monitoring, and data observability into a single solution, enabling data engineers to proactively manage data quality and eliminate data issues before they impact business decisions.

Leading companies across industries, including prominent players in banking, insurance, and healthcare, rely on iceDQ to continuously test, monitor, and observe their data-driven systems. This ensures trustworthy data that fuels informed decision-making and drives business success.

iceDQ Use Cases

  • Data Testing
  • ETL & Data Warehouse Testing
  • Cloud Data Migration Testing
  • BI Report Testing
  • Big Data Lake Testing
  • System Migration Testing
  • Data Monitoring
  • Data Observability

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About the author

Sandesh Gawande

Sandesh Gawande is the Founder and CEO of iceDQ, a unified Data Reliability Platform for automated data testing, monitoring, and observability. With over 25 years of experience in data engineering and architecture, Sandesh has led large-scale data initiatives for Fortune 500 companies across banking, insurance, and healthcare, including Deutsche Bank, JPMorgan Chase, and MetLife.

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Sandesh Gawande - CTO iceDQ

Sandesh Gawande

CEO and Founder at iceDQ.
First to introduce automated data testing. Advocate for data reliability engineering.

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