Data registers

A standard version of SART 2 involves all the data registers required by the Polish Act on anti-money laundering and counter-terrorism financing. They have been designed to collect, analyse and to make accessible data related to application of financial safety measures, analysis results reporting and obligatory reporting that is required by the GIIF (General Inspector of Financial Information) Transactions Register, as well as documentation and reporting of suspicious transactions and making accessible the data to the surveillance authorities.

The system automates the updating of Central Subject Registry, collecting such data as:

• customer, contractor, beneficial owner and real beneficial owner personal data, serves also as a identity cards repository;
  
  
• details on corporate customers taking part in bank activities;
  
  
• linkages between CRP objects: persons and legal entities as well as data related to those objects, including legal entities division according to PKD (Polish Classification of Economic Activities), politically exposed persons (PEPs) and persons listed in them, shares owned by legal entities, company managers, etc.;
  
  
• National Court Register (NKP) number, Register of National Economy (REGON) number, Tax Identification Number (NIP) and National Identification Number (PESEL), watchlists (World-Check, Dow Jones, GIIF, UE checklists, etc.).

The data address all the legal requirements:

• detection and profiling of customer and transaction;
  
  
• detection and profiling of entities taking part in bank activities;
  
  
• highlighting of hidden linkages between entities, e.g. ownership, professional or family relationships;
  
  
• identification of real beneficial owner;
  
  
•  monitoring and verifying data of obligated institution customers.

Data analysis

The SART 2 is a unique product in the software market that adheres to the legal regulations concerning Cash Flow Chains Analysis and detecting on that basis complex money laundering schemes. Thanks to the data structure in the SART 2 system, customer’s business connections are easily analysed and linkages between entities determined.

The issue comprises the identification of a real beneficial owner and linkages between transactions, accounts and entities resulting from money flow between accounts, as well as where the money come from originally. It can be stressed here that those structures allow a range of analyses actually unavailable to other commercial tools.

Operational risk management in anti-money laundering prevention belongs to the most important requests demanded by the new Act. According to the Act the key decision making procedures must be based on risk analysis towards possible money laundering.

The SART 2 solution addresses the following key requirements covering money laundering:

• automates the generating of money laundering risk events, among other things, identifying of customer’s rare and non-standard events;
  
  
• handles events related to risk through pre-defined workflows (analysis, reporting, event monitoring);
  
  defines money laundering schemes and automatically identifies, on the ground, complex events corresponding to those schemes;
  
  
• evaluates risk in following fields: customer, account, transaction and, on the ground, estimates the risk level, also automated customer segmentation in this regard.

The SART 2 solution automates the creation and filing of report in a number of different, almost any, formats. Moreover, it comprises Transaction Registry meeting the requirements of Ministry of Finance Ordinance, concerning transaction registry template, the way of keeping it and the way of delivering the its data to the General Inspector of Financial Information (GIFI). It can be emphasized that filling in the GIIF Registry cards is fully automated, on the basis of SART 2 system registers. Moreover, the system fills in also linked transactions cards, which requires specifying of all transactions linked to the registered transaction.