U.S. patent application number 13/096195 was filed with the patent office on 2011-08-18 for systems and methods for managing risk associated with a geo-political area.
Invention is credited to David Lawrence.
Application Number | 20110202457 13/096195 |
Document ID | / |
Family ID | 46299413 |
Filed Date | 2011-08-18 |
United States Patent
Application |
20110202457 |
Kind Code |
A1 |
Lawrence; David |
August 18, 2011 |
Systems and Methods for Managing Risk Associated with a
Geo-Political Area
Abstract
Methods and systems are presented for managing Risks, including
regulatory and reputational risk. The methods can be implemented in
a computer and include receiving data descriptive of informational
artifacts with content related to at least one of reputational and
regulatory risk into the computer system. The computer system can
have one or more geo-political areas defined within it. The
computer system can also receive data descriptive of details of a
financial transaction, wherein the details include an indication of
at least one geopolitical area associated with the financial
transaction. At least one informational artifact related to at
least one of reputational and regulatory risk can be associated
with the at least one geopolitical area associated with the
financial transaction and the computer system can generate a report
comprising data descriptive of the informational artifacts
associated with the at least one geopolitical area associated with
the financial transaction.
Inventors: |
Lawrence; David; (New York,
NY) |
Family ID: |
46299413 |
Appl. No.: |
13/096195 |
Filed: |
April 28, 2011 |
Related U.S. Patent Documents
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Application
Number |
Filing Date |
Patent Number |
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10459655 |
Jun 11, 2003 |
7958027 |
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13096195 |
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10074584 |
Feb 12, 2002 |
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10459655 |
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10021124 |
Oct 30, 2001 |
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10074584 |
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09812627 |
Mar 20, 2001 |
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10021124 |
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60387849 |
Jun 11, 2002 |
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Current U.S.
Class: |
705/39 |
Current CPC
Class: |
G06Q 40/10 20130101;
G06Q 40/025 20130101; G06Q 20/10 20130101; G06Q 40/00 20130101;
G06Q 40/04 20130101; G06Q 40/08 20130101; G06Q 30/02 20130101; G06Q
40/06 20130101 |
Class at
Publication: |
705/39 |
International
Class: |
G06Q 40/00 20060101
G06Q040/00 |
Claims
1-15. (canceled)
16. A computer implemented method for managing risk associated with
a financial transaction, the method comprising: defining within a
computer system one or more policies, each policy associated with
one or more geo-political area; receiving data descriptive of a
financial transaction comprising, at least, data descriptive of one
or more geo-political areas associated with the financial
transaction; and transmitting the policy associated with the
geo-political area to a person responsible for regulatory
compliance of the financial transaction.
17. The method of claim 16 wherein the financial transaction
comprises a fund transfer between with a country of origination
different from the destination country.
18. The method of claim 16 wherein the financial transaction
comprises investment banking.
19-20. (canceled)
Description
CROSS REFERENCE TO RELATED APPLICATIONS
[0001] This application claims the benefit of the filing date of
U.S. Provisional applications No. 60/387,849 entitled "Jurisdiction
Related Fund Transfer Risk Management", filed Jun. 11, 2002. This
application is a continuation-in-part of a prior application
entitled "Risk Management Clearinghouse", filed Feb. 12, 2002, and
hearing the Ser. No. 10/074,584 which is a continuation-in-part of
a prior application also entitled "Risk Management Clearinghouse"
filed Oct. 30, 2001, and bearing the Ser. No. 10/021,124, which is
also a continuation-in-part of a prior application entitled
"Automated Global Risk Management" filed Mar. 20, 2001, and bearing
the Ser. No. 09/812,627, all of which are relied upon and
incorporated by reference.
FIELD
[0002] The present invention relates to computerized database and
communication systems. In particular, the present invention relates
to systems and methods to facilitate managing risk associated with
a geo-political area.
BACKGROUND
[0003] World events and surreptitious activities have increased the
need to "Know Your Customer" in order to minimize risks associated
with conducting business with, or on behalf of, a particular person
or organization. The present invention focuses on ascertaining and
managing risks associated with a geo-political area, such as a
country, region or a street address.
[0004] As money-laundering and related concerns have become
increasingly important public policy concerns, regulators have
attempted to address these issues by imposing increasing formal and
informal obligations upon Risk Bearing Institutions. Government
regulations authorize a broad regime of record-keeping and
regulatory reporting obligations on covered Risk Bearing
Institutions as a tool for the federal government to use to fight
drug trafficking, money laundering, and other crimes. The
regulations may require Risk Bearing Institutions to file currency
and monetary instrument reports and to maintain certain records for
possible use in tax, criminal and regulatory proceedings. Such a
body of regulation is designed chiefly to assist law enforcement
authorities in detecting when criminals are using banks and other
Risk Bearing Institutions as intermediaries for, or to hide the
transfer of funds derived from, criminal activity.
[0005] Obligations include those imposed by the Department of the
Treasury and the federal banking regulators which adopted
suspicious activity report ("SAR") regulations. SAR regulations
require that Risk Bearing Institutions file SARs whenever an
institution detects a known or suspected violation of federal law,
or a suspicious transaction related to a money laundering activity
or a violation of the Bank Secrecy Act ("BSA"). The regulations can
impose a variety of reporting obligations on Risk Bearing
Institutions. Perhaps most broadly relevant for the present
invention, current regulations require a Risk Bearing Institution
to report transaction which aggregate to $5,000 and which involve
potential money laundering or violations if the institution, knows,
suspects, or has reason to suspect that the transaction involves
funds from illegal activities, is designed to disguise such funds,
has no business or legitimate purpose, or is simply not the sort of
transaction in which the particular customer would normally be
expected to engage, and the institution knows of no reasonable
explanation for the transaction after examining the available
facts.
[0006] Federal regulators have made clear that the practical effect
of these requirements is that Risk Bearing Institutions are subject
to significant obligations to "know" their customer and to engage
in adequate monitoring of transactions.
[0007] Bank and non-bank Risk Bearing Institutions, including:
investment banks; merchant banks; commercial banks; securities
firms, including broker dealers securities and commodities trading
firms; asset management companies, hedge funds, mutual funds,
credit rating funds, securities exchanges and bourses,
institutional and individual investors, law firms, accounting
firms, auditing firms, any institution the business of which is
engaging in financial activities as described in section 4(k) of
the Bank Holding Act of 1956, and other entities subject to legal
and regulatory compliance obligations with respect to money
laundering, fraud, corruption, terrorism, organized crime,
regulatory and suspicious activity reporting, sanctions, embargoes
and other regulatory risks and associated obligations, hereinafter
collectively referred to as "Risk Bearing Institutions," typically
have few resources available to them to assist in the
identification of present or potential risks associated with
business transactions.
[0008] Generally, compliance officers and other Risk Bearing
Institution personnel have few resources available to assist them
with the identification of present or potential global risks
associated with a particular investment or trading transaction.
Risks can be multifaceted and far reaching. The amount of
information that needs to be considered to evaluate whether an
international entity poses a significant risk or should otherwise
be restricted, is substantial.
[0009] However, Risk Bearing Institutions do not have available a
mechanism which can provide real time assistance to assess a risk
factor associated with an international transaction, or otherwise
qualitatively manage such risk. In the event of investment
problems, it is often difficult to quantify to regulatory bodies,
shareholders, newspapers and/or other interested parties, the
diligence exercised by the Risk Bearing Institution to properly
identify and respond to risk factors. Absent a means to quantify
good business practices and diligent efforts to contain risk, a
Risk Bearing Institution may appear to be negligent in some
respect.
SUMMARY
[0010] To alleviate problems inherent in the prior art, the present
invention introduces systems and methods to facilitate ascertaining
and managing Risks associated with a geo-political area.
[0011] According to some embodiments, methods and systems are
presented for managing Risks, including regulatory and reputational
risk. The methods can be implemented in a computer and include
receiving data descriptive of informational artifacts with content
related to at least one of reputational and regulatory risk into
the computer system. The computer system can have one or more
geo-political areas defined within it. The computer system can also
receive data descriptive of details of a financial transaction,
wherein the details include an indication of at least one
geopolitical area associated with the financial transaction. At
least one informational artifact related to at least one of
reputational and regulatory risk can be associated with the at
least one geopolitical area associated with the financial
transaction and the computer system can generate a report
comprising data descriptive of the informational artifacts
associated with the at least one geopolitical area associated with
the financial transaction.
[0012] Some embodiments can include a computer system which
receives data descriptive of informational artifacts with content
related to Risks, such as for example, at least one of reputational
and regulatory risk. The computer system can have one or more
geo-political areas defined within it and can associate one or more
of the informational artifacts with the one or more defined
geo-political areas. The computer system can also receive details
of a financial transaction, wherein the details include an
indication of at least one geopolitical area associated with the
financial transaction. One or more informational artifacts related
to Risk, such as reputational and regulatory Risk can be associated
with the at least one geopolitical area associated with the
financial transaction. A report can be generated which includes
data descriptive of the informational artifacts associated with the
at least one geopolitical area associated with the financial
transaction.
[0013] With these and other advantages and features of the
invention that will become hereinafter apparent, the invention may
be more clearly understood by reference to the following detailed
description of the invention, the appended claims, and the drawings
attached herein.
BRIEF DESCRIPTION OF THE DRAWINGS
[0014] FIG. 1A is a block diagram overview of some implementations
of the present invention.
[0015] FIG. 1B is a block diagram of some implementations of the
present invention which include funds transfer.
[0016] FIG. 2A-2D illustrate flow charts of various methods
according to some embodiments of the present invention.
[0017] FIG. 3 is a block diagram overview of a communication system
according to some embodiments of the present invention.
[0018] FIG. 4 is a block diagram of a communication controller
according to an embodiment of the present invention.
[0019] FIG. 5 illustrates a user interface that can be utilized
with some embodiments of the present invention.
[0020] FIG. 6 illustrates a graphical user interface that can be
utilized with some embodiments of the present invention.
[0021] FIG. 7 is a tabular representation of a portion of a
geo-political area information database according to some
embodiments of the present invention.
[0022] FIG. 8 is a tabular representation of a portion of a risk
management database according to some embodiments of the present
invention.
DETAILED DESCRIPTION
[0023] The present invention provides methods and systems
implemented by a computer system to assess and manage risk
associated with one or more geographic areas. In some embodiments,
the present invention can be used in conjunction with a Risk
Management Clearinghouse for associating informational artifacts
with identified risk criteria.
[0024] A computerized system gathers and stores data descriptive of
informational artifacts in a database or other data storing
structure and relates the information to risk criteria associated
with a jurisdiction or other geo-political area. A user can supply
details of a financial transaction to the database to assess risk
associated with the financial transaction. The computerized system
relates the details supplied with specified risk criteria and
informational artifacts in order to generate a report that
correlates informational artifacts with risk criteria and the
details of the financial transaction. In some embodiments, the
report can be utilized by a Risk Bearing Institution to assess
Risks associated with a particular financial transaction, or to
assess aggregate Risks faced by the Risk Bearing Institution. Other
embodiments can include an assessment from a user's perspective
seeking to assess potential risk with a particular financial
transaction, with a particular subject matter of a Financial
Transaction, with a Risk Bearing Institution involved or other
subject matter.
[0025] Risks associated with a Financial Transaction that involves
international jurisdictions can be greatly increased due to the
difficulty in gathering and accessing pertinent data on a basis
timely to managing risk associated with the transaction. As part of
due diligence associated with arranging, providing or conducting a
Financial Transaction, there is a growing importance for a Risk
Bearing Institution to "Know Their Customer" including whether a
Transaction Participant is contained on a list of restricted
persons published or maintained by a law enforcement agency, the
Office of Foreign Access Control (OFAC), the Treasury Office or
other government or industry organization or entity involved with
regulatory tasks or containment of Risks.
[0026] In some embodiments, a rating, such as a risk quotient can
be generated to readily indicate a level of Risk associated with a
particular financial transaction or Transaction Participant. The
risk quotient can be based upon a weighted algorithm applied to the
Risk criteria and informational artifacts. The risk quotient can be
made available on a periodic basis, on demand, in real time, in
response to an event such as executing a Financial Transaction, or
according to some other request. Some embodiments can also include
generation of suggested actions commensurate with ascertained
Risks.
DEFINITIONS
[0027] To aid in the description of the present invention, the
following definitions can apply to terms utilized throughout this
document:
[0028] Financial Transaction: a Financial transaction refers to any
action that anticipates a transfer of money from a first set of one
or more Transaction Participants to a second set of one or more
Transaction Participants. Examples of Financial Transactions can
include: investment and merchant banking, public and private
financing, commodities and a securities trading, commercial and
consumer lending, asset management, rating of corporations and
securities, public and private equity investment, public and
private fixed income investment, listing to companies on a
securities exchange and bourse, employee screening, auditing of
corporate or other entities, legal opinions relating to a corporate
or other entity, or other business related transactions.
[0029] Geographic Designation: Geographic Designation refers to a
political or geographic indication of an area of the globe. As such
a Geographic Designation can include any indication of a geographic
area, such as, for example: a street address, a mailing address, a
global positioning system designation, a longitude and latitude
coordinate, a tax map number, or other description of a
geo-political area, a national boundary; a jurisdictional boundary;
an area defined by a geographic attribute, such as, for example,
the great lakes districts in Africa, or the diamond corridor; or
other means to indicate an area on Earth.
[0030] Informational Artifact: Informational Artifact refers to a
media item that contains information that can be interpreted into a
humanly ascertainable form. Examples of Informational Artifacts
include: a news article, a news feed portion, a video segment, a
newscast, a report, an identifiable document, an agency listing, a
list, a government publication, other identifiable publication, a
sound byte, a sound recording, or other media item.
[0031] Risk Bearing Institution: a Risk Bearing Institution refers
to any person, entity, company, corporation or statutory "person"
in the business of providing Financial transactions. As such a Risk
Bearing Institution can include, for example: a securities broker,
a retail bank, a commercial bank, investment and merchant bank,
private equity firm, asset management company, a mutual fund
company, a hedge fund firm, insurance company, a credit card
issuer, retail or commercial financier, a securities exchange, a
regulator, a money transfer agency, bourse, an institutional or
individual investor, an auditing firm, a law firm, any institution
the business of which is engaging in financial activities as
described in section 4(k) of the Bank Holding Act of 1956 or other
entity or institution who may be involved with a financial
transaction or other business transaction or any entity subject to
legal and regulatory compliance obligations with respect to money
laundering, fraud, corruption, terrorism, organized crime,
regulatory and suspicious activity reporting, sanctions, embargoes
and other regulatory risks and associated obligations.
[0032] Risks: Risks associated with a financial transaction can
include factors associated with security risk, financial risk,
legal risk, regulatory risk and reputational risk. A Security Risk
refers to breach of a safety measure that may result in
unauthorized access to a facility; unauthorized access to data;
physical harm, including threat of immediate risk of harm to a
person or goods. Financial Risk refers to factors indicative of
monetary costs that the Risk Bearing Institution or a Transaction
Participant may be exposed to as a result of a particular Financial
Transaction. Monetary costs can be related to fines, forfeitures,
costs to defend an adverse position, lost revenue, or other related
potential sources of expense. Regulatory Risk refers to factors
that may cause the Risk Bearing Institution or Transaction
Participant to be in violation of rules put forth by a government
entity or regulatory agency. Reputational risk relates to harm that
a Risk Bearing Institution or Transaction Participant may suffer
regarding its professional standing in an industry or the public
eye. A Risk Bearing Institution and Transaction Participant can
suffer from being associated with a situation that may be
interpreted as contrary to an image of diligence, honesty and
forthrightness.
[0033] Risks may be related to the duty to disclose material
information, to report and possibly prevent: fraud, money
laundering, foreign corrupt practices, bribery, embargoes and
sanctions. Timely access to relevant data on which to base a
regulatory or reputational Risk related action can be critical to
conducting business and comply with regulatory requirements such as
those set forth by the Patriot Act in the United States.
[0034] Risk Management Clearinghouse (RMC): RMC refers to
computerized systems and methods for managing Risks and associating
information and/or informational artifacts useful for quantifying
Risk with a Risk subject, as more fully described in the related
patent application Ser. No. 10/074,584 entitled "Risk Management
Clearinghouse" filed Feb. 12, 2002, and U.S. patent application
Ser. No. 10/021,124 entitled "Risk Management Clearinghouse" filed
Oct. 30, 2001.
[0035] Risk Quotient: Risk Quotient refers to a quantitative value
of an amount of Risk, a Risk Quotient can be based upon a weighted
algorithm applied to the Risk criteria and informational
artifacts.
[0036] Transaction Participant: Transaction Participant refers to a
person who will partake in a Financial transaction.
Elements
[0037] Referring now to FIG. 1A, a block diagram including elements
of some embodiments of the present invention is illustrated. A
Geo-political area Risk Controller (GLR Controller) 101, receives
data descriptive of one or more geo-political areas 110 from a user
122. The GLR Controller 121 can include a computerized system
programmed or otherwise functioning to perform the various
inventive functions described herein. A detailed description of
some embodiments of a GLR Controller 121 are disclosed herein with
particular implementations discussed in relation to FIGS. 3 and
4.
[0038] An user device 122 can be any electronic communications
device that enables a human to interact with the GPA Controller
121. The user can transmit the data descriptive of a geo-political
area to the GPA Controller 121 alone or combined with other data
containing details relating to a financial transaction. For,
example, as part of a standard processing procedure, a user can
input data 126 that is related to the execution of a financial
transaction into a user device 122. The user device 22 can then
transmit, or otherwise convey the transaction data to a transaction
system 123 which will process the transaction. The user device 22
can also convey a portion of the transaction data that is
descriptive of a geo-political area 110 to the GLR Controller 121.
In some embodiments, the GLR Controller can receive the data
descriptive of one or more geo-political areas 110 directly from
the transaction system 123.
[0039] Some embodiments can also include the GPA Controller 121
receiving additional information from a RMC 124. The RMC can in
supply data gathered from a number of sources and structured
according to risk criteria. The data from the RMC can include data
gathered from numerous sources, such as, for example: a list
generated by the Office of Foreign Assets Control (OFAC) 401,
including their sanction and embargo list; a list generated by the
U.S. Commerce Department 402; a list of international "kingpins"
generated by the U.S. White House 403; a list generated by a
foreign counterpart to a U.S entity 404; U.S. regulatory actions
405; or other information source 407 such as a foreign government,
US adverse business-related media reports, US state regulatory
enforcement actions, international regulatory enforcement actions,
international adverse business-related media reports, a list of
terrorist organizations, a list of politically connected
individuals and military leaders, a list of U.S. and international
organized crime members and affiliates, or a list of recognized
high risk countries. Court records or other references relating to
fraud, bankruptcy, professional reprimands or a rescission of a
right to practice, suspension from professional ranks, disbarment,
prison records or other sources of suspect behavior can also be
included as a source of informational data and artifacts, as can
public documents and publications such as newspapers, periodicals,
news feeds, internet postings, government filings or other source
of information. Many embodiments can also include information data
sources which are various foreign equivalents to those listed above
or any other international source.
[0040] Data relating to informational artifacts 106 can be varied
according to a source or type of data and generally include any
data which can be presented as humanly discernable information. It
can also include actual copies of artifacts or portions thereof,
such as, for example, a copy of a government report, a news
article, a document, a transcript, a cite, a court record, or other
article. Embodiments can include data relating to informational
artifacts that is periodically updated, constantly updated in real
time, or updated in response to a request.
[0041] The GLR Controller 121 can transmit the data descriptive of
one or more geo-political areas 110 to the RMC 124. The RMC 124 can
determine which data relating to informational artifacts gathered
by the RMC 124 are associated with the one or more geo-political
area related risk criteria and the information descriptive of a
financial transaction 107 and generate a report and/or a suggested
action based upon the data received. The data relating to
informational artifacts 106 can be associated with a risk criteria
or other subject with programmed data association techniques, such
as, for example, keyword search, fuzzy logic, artificial
intelligence programs, full text, numerical value, financial value,
coded entry or other well known or proprietary forms of data
manipulation.
[0042] Output from the GLR Controller 121 can include a risk
indication 112 which can be transmitted to one or both of the user
device 122 and the transaction system 123. The risk indication can
include a risk quotient or other quantitative value of an amount of
risk associated the transaction, an instruction, a suggested action
or other indicator.
[0043] Some embodiments can include other risk indications 112
output by the GPA Controller 121 such as, for example, a report
containing data descriptive of a geo-political area 110, risk
criteria and informational artifacts. Reports can generated that
are conducive to the needs of a particular recipient or the report.
For example, a report can be generated for a compliance department
that includes risk indications for multiple transactions, or for a
market participant which relate to a particular transaction or
deal. Embodiments can therefore include reports generated for a
graphical user interface, hardcopy, facsimile, e-mail, messaging or
other communication with any humanly or machine discernable data
and/or artifacts. In some embodiments, output can include
transmitting the risk criteria related data to a designated
recipient in any humanly or machine discernable data and/or
artifacts.
[0044] A user, such as a Risk Bearing Institution, will often be
closely regulated. As a result Risk Bearing Institutions are
exposed to significant risks from their obligations of compliance
with the law and to prevent, detect and, at times, report potential
violations of laws, regulations and industry rules ("laws").
Amongst other usefulness, reports generated by the GPA Controller
121 and/or the RMC 124 can be utilized to address Risks that may be
raised by regulators.
[0045] Referring now to FIG. 1B a block diagram of some exemplary
embodiments of the present invention is illustrated. In the example
illustrated, a GPA Controller 121 and an RMC 124 can facilitate
management of Risk associated with a wire transfer or other
electronic transfer of funds. Embodiments can include, an GPA
Controller 121 linked to a Funds Transfer Provider 107 such that
the GPA Controller 121 can receive informational data descriptive
of a fund transfer 106 from one or more Financial Institutions
101-102 involved in the fund transfer. The GPA Controller 121 can
provide an indication of the amount of Risk that is associated with
the fund transfer.
[0046] The GPA Controller 121 can determine an amount of Risk
associated with a fund transfer based upon internal processes and,
in some embodiments, base upon informational artifacts and other
related information provided by a RMC 124. The GPA Controller 121
and RMC 124 can evaluate the fund transfer information 106,
including an assessment of a geo-political area associated with the
originator 103 and a geo-political area associated with a recipient
104. The fund transfer information 106 can be assessed for
indications of high Risk. The GPA Controller 121 can notify one or
more Financial Institutions involved of any high Risk
implications.
[0047] For example, a Financial Institution 101 may set up a
compliance program that proscribes the Financial Institution 101
from conducting business, including a fund transfer, that involves
a set of certain geo-political areas and requires additional due
diligence for another set of geo-political areas. The GPA
Controller 121 may automatically receive fund transfer information
106 from the Financial Institution 101 for each fund transfer the
Financial Institution is going to execute. The GPA Controller 121
can assess the fund transfer information 106 to ascertain if any
geo-political area involved is proscribed or requires additional
due diligence. In addition, some embodiments of the present
invention may conduct a RMC 124 search based upon the fund transfer
information and incorporate the results of the RMC 124 search into
feedback presented to the Financial Institution 101.
[0048] A transfer of funds can include a transaction, or series of
transactions, which can begin with an originator's 103 payment
order, made for the purpose of making payment to a recipient 104
who is a beneficiary of the order. A payment order can be issued by
an originator's 103 bank or an intermediary bank (a first Financial
Institution 101) intended to carry out the originator's 103 payment
order. A funds transfer is completed by acceptance by the
recipient's 104 bank (a second Financial Institution 102) of a
payment order for the benefit of the beneficiary of the
originator's payment order. Also within the scope of this invention
are any other funds transfer including those made through an
automated clearinghouse, an automated teller machine, or a
point-of-sale system.
[0049] An originator 103 can include a sender of a first payment
order in a funds transfer. An originator's bank can include a
receiving bank to which a payment order of the originator 103 is
issued if the originator 103 is not a bank or foreign bank, or the
originator 103 if the originator 103 is a bank or foreign bank.
[0050] A payment order can include an instruction of a originator
103 to a receiving bank, which can be transmitted orally,
electronically, or in writing, to pay, or to cause another bank or
foreign bank to pay, a fixed or determinable amount of money to a
beneficiary such that the receiving bank is to be reimbursed by
debiting an account of, or otherwise receiving payment from the
originator 103; and the instruction is transmitted by the
originator 103 directly to the receiving Financial Institution 102
or to an agent, funds transfer system, or communication system for
transmittal to the receiving Financial Institution 102.
[0051] A receiving Financial Institution 102 can include a bank or
foreign bank to which a originator's 103 instruction is addressed.
A receiving financial institution 102 can include a financial
institution or foreign financial agency to which the originator's
instruction is addressed. The term receiving financial institution
can include a receiving bank. A recipient can include a person to
be paid by the recipient's financial institution, and can also
include a beneficiary a recipient's financial institution can
include a financial institution or foreign financial agency
identified in a transmittal order in which an account of the
recipient is to be credited pursuant to the transmittal order or
which otherwise is to make payment to the recipient if the order
does not provide for payment to an account. The term recipient's
financial institution can, in some embodiments, include a
beneficiary's bank.
[0052] A transaction. can include any transfer of pecuniary value,
including, for example, a purchase, sale, loan, pledge, gift,
transfer, delivery, or other disposition, and with respect to a
financial institution includes a deposit, withdrawal, transfer
between accounts, exchange of currency, loan, extension of credit,
purchase or sale of any stock, bond, certificate of deposit, or
other monetary instrument or investment security, purchase or
redemption of any money order, payment or order for any money
remittance or transfer, or any other payment, transfer, or delivery
by, through, or to a financial institution, by whatever means
effected. Similarly, a "transaction in currency" can include a
transaction involving the physical transfer of currency from one
person to another.
[0053] A transmittal of funds can include a series of transactions
beginning with a transmitter's transmittal order, made for the
purpose of making payment to a recipient of the order. The term can
include a transmittal order issued by a transmitter's financial
institution or an intermediary financial institution intended to
carry out the transmitter's transmittal order. The term transmittal
of funds includes a funds transfer. A transmittal of funds can be
completed by acceptance by the recipient's financial institution of
a transmittal order for the benefit of the recipient of the
transmitter's transmittal order. A transmittal order can include a
payment order and is an instruction of a originator to a receiving
financial institution, transmitted orally, electronically, or in
writing, to pay, or cause another financial institution or foreign
financial agency to pay, a fixed or determinable amount of money to
a recipient. Typically an instruction will not state a condition to
payment to the recipient other than time of payment and the
receiving financial institution is to be reimbursed by debiting an
account of, or otherwise receiving payment from, the
originator.
[0054] A transmitter can include the originator 103 of the first
transmittal order in a transmittal of funds. Typically, the term
transmitter includes an originator 103. A transmitter's financial
institution 101 can include the receiving financial institution 101
to which the transmittal order of the transmitter is issued if the
transmitter is not a financial institution 101 or foreign financial
agency, or the transmitter if the transmitter is a financial
institution 101 or foreign financial agency.
[0055] A transfer participant, including, an originator 103 and a
recipient 104, can include, for example: an individual, a business,
a corporation, a government entity, a charity, a church, or any
other legal entity that may be involved in a transfer of funds.
[0056] The fund transfer information 106 can include: information
identifying the transfer participants 103-104 involved; an account
number or other identifier of an account supplying funds to be
transferred; an account number or other identifier of a recipient
account; an address and/or other identifying information of a
transfer participant originating a fund transfer, an address and/or
other identifying information of a transfer participant receiving
funds via a fund transfer; a country or other jurisdiction from
which the fund transfer originates; a country or other jurisdiction
that is a destination of the fund transfer, any intermediary
jurisdictions that may be involved with the fund transfer; a
transaction identification number; any annotations included in the
fund transfer and any other information related to the transfer of
funds.
[0057] A Funds Transfer Provider 107 can include any entity with
resources, facilities, authorizations or other factors required to
effect an electronic transfer of funds. For example, a funds
transfer institution can include a government entity, such as the
U.S. Federal Reserve's Fedwire or a private institution, such as
Western Union, CHIPS or SWIFT.
[0058] Some embodiments can include a Financial Institution 101-102
maintaining a record of each request, instruction or piece of
advice received or given regarding any transaction resulting, or
intended to result in the transfer of currency or other monetary
instruments, funds, checks, investment securities, or credit. Some
embodiments can also include a record of each advice, request, or
instruction given to another Financial Institution 101-102 or other
person located within or without the United States, regarding a
transaction intended to result in the transfer of funds, currency
or other monetary instruments, checks, investment securities, or
credit.
[0059] Risk related criteria, which a Financial Institution 101-102
can record and forward to a RMC 124 can include informational data,
such as, for example: an address or other indication of a
geo-political area associated with the originator 103, transmitter,
recipient 104, beneficiary, intermediary or other associated party;
the name of the originator 103, transmitter, recipient 104,
beneficiary, intermediary or other associated party an amount of a
payment order; or other money transfer; an execution date of a
payment order or other money transfer; payment instructions
received from an originator or intermediary related to the payment
order or other money transfer; the identity of the beneficiary's or
recipient's bank; and any account numbers related to the
transaction; any other specific identifier of an originator or
beneficiary; if a payment order is made in person, any verification
of the identity of the person placing the payment order. If it
accepts a payment order, participant Financial Institution can
obtain and retain data descriptive of the transaction, such as, for
example, a record of the name and address of an originator,
transmitter, intermediary, recipient and/or beneficiary, a type of
identification reviewed for any person, a number associated with an
identification document (e.g., driver's license), a record of the
person's taxpayer identification number (e.g., social security or
employer identification number, alien identification number or
passport number) a country of issuance of an identifying document,
or a notation in the record of the lack thereof.
[0060] Some embodiments can also include tracking each
jurisdiction, country, sovereign area, nation or other political
designation involved in each or any step of a transaction. For
example, for any or each transaction, an origination and
designation or recipient jurisdiction, as well as the jurisdiction
of any intermediary jurisdiction, can be determined and forwarded
to a GPA Controller 121 and a RMC 124 to conduct a risk management
assessment.
[0061] In another aspect, some embodiments can include establishing
and maintaining records related to any or all Transaction Parties,
such as a transaction originator 103, transmitter, intermediary,
recipient 104, beneficiary, or other related party. For example,
for any payment or other transaction, if the proceeds are delivered
in person to a beneficiary or its representative or agent, the
beneficiary's bank can verify the identity of a person receiving
the proceeds and obtain and retain a record of the name and
address, the type of identification reviewed, the number of an
identification document (e.g., driver's license), as well as a
record of the person's taxpayer identification number (e.g., social
security or employer identification number) or, if none, alien
identification number or passport number and country of issuance,
or a notation in the record of the lack thereof. If the
beneficiary's bank has knowledge that the person receiving the
proceeds is not the beneficiary, the beneficiary's bank can obtain
and retain a record of the beneficiary's name and address, as well
as the beneficiary's taxpayer identification number (e.g., social
security or employer identification number) or, if none, alien
identification number or passport number and country of issuance,
if known by the person receiving the proceeds, or a notation in the
record of the lack thereof.
[0062] Some embodiments of the present invention can closely follow
terms and definitions of applicable law. Accordingly, embodiments
can include an acceptance occurring when a receiving financial
institution, other than the recipient's financial institution,
accepts a transmittal order by executing the transmittal order. A
recipient's financial institution can accept a transmittal order
for example, by paying the recipient, notifying the recipient of
the receipt of the order or by otherwise becoming obligated to
carry out the order. Embodiments can also include an RMC search
being performed on any person who transports, mails, ships or
receives; is about to or attempts to transport, mail or ship; or
causes the transportation, mailing, shipment or receipt of monetary
instruments.
[0063] In another aspect, embodiments can be implemented in which a
monetary instrument can include: currency; a traveler's check in
any form; a negotiable instrument (including a personal check,
business check, official bank check, cashier's check, third-party
check, promissory note, and/or money order) any of which may be in
bearer form, endorsed without restriction, made out to a fictitious
payee, or otherwise in such form that title thereto passes upon
delivery; an incomplete instrument, including a personal check,
business check, official bank check, cashier's check, third-party
check, promissory note; securities or stock in bearer form or
otherwise in such form that title thereto passes upon delivery; or
other form or vehicle which can act to transfer monetary value. In
some forums a monetary instrument may not include a warehouse
receipt or bill of lading, however such instruments can fall within
the scope of this invention as it may be useful for Risk management
to perform a RMC search information contained in any of the
instruments listed routinely, periodically or upon request.
[0064] Some embodiments can also include currency defined as coin
and paper money of the United States or of any other country that
is designated as legal tender and that circulates and is
customarily used and accepted as a medium of exchange in the
country of issuance. Embodiments can therefore anticipate currency
including U.S. silver certificates, U.S. notes and Federal Reserve
notes. Currency can also include official foreign bank notes that
are customarily used and accepted as a medium of exchange in a
foreign country.
[0065] A beneficiary which, in some implementations, can be the
subject of a RMC search can include a person to be paid by the
beneficiary's bank, wherein the beneficiary's bank can include the
bank or foreign bank identified in a payment order in which an
account of the beneficiary is to be credited pursuant to an order
or which otherwise is to make payment to the beneficiary if the
order does not provide for payment to an account.
[0066] In some embodiments, a Risk Bearing Institution can
incorporate a GPA Controller 121 as part of legal and regulatory
oversight for various due diligence and know your customer
obligations imposed by regulatory authorities. The RMC system can
facilitate detection and reporting of potential violations of law,
and in some embodiments, address the "suitability" of a financial
transaction. Similarly, the RMC system can support a Risk Bearing
Institution's effort to meet requirements regarding the maintenance
of accurate books and records relating to conducted
transactions.
[0067] Information gathered from the diversity of data sources can
be aggregated into a searchable data storage structure. A source of
information can also be received and stored. In some instances a
subscriber may wish to receive information regarding the source of
information received. Gathering data into an aggregate data
structure, such as a data warehouse allows a RMC system to have the
data readily available for processing a risk management search
associated with a risk subject. Aggregated data 108 can also be
scrubbed or otherwise enhanced.
[0068] In some embodiments of enhancing data, data scrubbing can be
utilized to implement a data warehouse comprising the aggregate
data structure. The data scrubbing takes information from multiple
databases and stores it in a manner that gives faster, easier and
more flexible access to key facts. Scrubbing can facilitate
expedient access to accurate data commensurate with the critical
business decisions that will be based upon the risk management
assessment provided.
[0069] Various data scrubbing routines can be utilized to
facilitate aggregation of risk variable related information. The
routines can include programs capable of correcting a specific type
of mistake, such as an incomprehensible address, or clean up a full
spectrum of commonly found database flaws, such as field alignment
that can pick up misplaced data and move it to a correct field or
removing inconsistencies and inaccuracies from like data. Other
scrubbing routines can be directed directly towards specific legal
issues, such as money laundering or terrorist tracking
activities.
[0070] For example, a scrubbing routine can be used to facilitate
various different spelling of one name. In particular, spelling of
names can be important when names have been translated from a
foreign language into English. For example, some languages and
alphabets, such as Arabic, have no vowels. Translations from Arabic
to English can be very important for Risk Bearing Institutions
seeking to be in compliance with lists supplied by the U.S.
government that relate to terrorist activity and/or money
laundering. A data scrubbing routine can facilitate risk variable
searching for multiple spellings of an equivalent name or other
important information. Such a routine can enhance the value of the
aggregate data gathered and also help correct database flaws.
Scrubbing routines can improve and expand data quality more
efficiently than manual mending and also allow a subscriber to
quantify best practices for regulatory purposes.
[0071] Retrieving information related to risk variables from the
aggregated data is an operation with the goal to fulfill a given a
request. In order to process request against a large document set
of aggregated risk data with a response time acceptable to the
user, it may be necessary to utilize an index based approach to
facilitate acceptable response times. A direct string comparison
based search may be unsuitable for the task.
[0072] An index file for a collection of documents can therefore be
built upon receipt of the new data and prior to a query or other
request. The index file can include a pointer to the document and
also include important information contained in the documents the
index points to. At query time, the RMC system can match the query
against a representation of the documents, instead of the documents
themselves. The RMC system can retrieve the documents referenced by
the indexes that satisfy the request if the subscriber submits such
a request. However it may not be necessary to retrieve the full
document as index records may also contain the relevant information
gleaned from the documents they point to. This allows the user to
extract information of interest without having to read the source
document.
[0073] At least two retrieval models can be utilized in fulfilling
a search request: a) Boolean, in which the document set is
partitioned in two disjoint parts: one fulfilling the query and one
not fulfilling it, and b) relevance ranking based in which all the
documents are considered relevant to a certain degree. Boolean
logic models use exact matching, while relevance ranking models use
fuzzy logic, vector space techniques (all documents and the query
are considered vectors in a multidimensional space, where the
shorter the distance between a document vector and the query
vector, the more relevant is the document), neural networks, and
probabilistic schema. In a relevance ranking model, low ranked
elements may even not contain the query terms.
[0074] Augmenting data can include data mining techniques that use
of sophisticated software to analyze and sift through the
aggregated data stored in the warehouse using techniques such as
mathematical modeling, statistical analysis, pattern recognition,
rule based trends or other data analysis tools. In contrast to
traditional systems that may have gathered and stored information
in a flat file and regurgitated the stored information when
requested, such as in a defined report related to a specific risk
subject or other ad hoc access concerned with a particular query at
hand, the present invention can provide risk related searching that
adds a discovery dimension by returning results that human operator
would find very labor and cognitively intense.
[0075] This discovery dimension supplied by the RMC system can be
accomplished through the application of augmenting techniques, such
as data mining applied to the risk related data that has been
aggregated. Data mining can include the extraction of implicit,
previously unknown and potentially useful information from the
aggregated data. This type of extraction can include unlooked for
correlations, patterns or trends. Other techniques that can be
applied can include fuzzy logic and/or inductive reasoning
tools.
[0076] For example, augmenting routines can include enhancing
available data with routines designed to reveal hidden data.
Revealing hidden data or adding data fields derived from existing
data can be very useful to risk management. For example, is
supplied data may not include an address for a person wishing to
perform a financial transaction; however a known telephone number
is available. Augmented data can include associating the telephone
number with a known geographic area. The geographic area may be a
political boundary, or coordinates, such as longitude and latitude
coordinates, or global positioning coordinates. The geographic area
identified can then be related to high risk or low risk areas.
[0077] Additional examples can include augmented data derived from
a telephone number which an RMC 124 or GPA Controller 121 may
associate with a particular geo-political area and which may in
turn may be associated with a person, account or a Financial
Transaction, as the case may be. Association with a geo-political
area may via the telephone number may indicate a higher level of
Risk.
[0078] Other embodiments can include the GPA Controller 121 or the
RMC 124 highlighting inconsistencies relating to geo-political
areas. For example, if a person in Europe wishes to perform a high
value transaction denominated in a currency of a mid-eastern Arab
nation through an African bank, augmented data may include a
statistical analysis of how often such a transaction takes place on
a global basis. The analysis may not place a value judgment on the
proposed transaction, but would present the statistics for a
compliance person to evaluate or for an automated process to flag
as an elevated Risk situation.
[0079] A log or other stored history can be created by the RMC
system and/or a GPA Controller 121, such that utilization of the
present invention can mitigate adverse effects relating to a
problematic Financial Transaction or geo-political area. Mitigation
can be accomplished by demonstrating to regulatory bodies,
shareholders, news media and other interested parties that
corporate governance is being addressed through tangible risk
management processes.
[0080] In some embodiments, the RMC system can also receive open
inquiries, such as, for example, from subscriber personnel not
necessarily associated with a particular transaction. An open query
may, for example, search for information relating to an individual
or circumstance not associated with a financial transaction and/or
provide questions, historical data, world event information and
other targeted information to facilitate a determination of risk
associated with a risk subject, such as a query regarding an at
risk entity's source of wealth or of particular funds involved with
an account or transaction in consideration. Measures can also be
put in place to insure that all such inquiries should be subject to
prevailing law and contractual obligations.
[0081] A query can also be automatically generated from monitoring
transactions being conducted by a transaction system 123. For
example, an transaction system 123 can electronically scan
transaction data for key words, entity names, geographic locales,
or other pertinent data. Programmable software can be utilized to
formulate a query according to suspect names or other pertinent
data and run the query against a database maintained by the RMC
system. Other methods can include voice queries via a telephone or
other voice line, such as voice over internet, fax, electronic
messaging, or other means of communication. A query can also
include direct input into a GPA Controller 121 or RMC 124, such as
through a graphical user interface (GUI) with input areas or
prompts.
[0082] Prompts or other questions proffered by the GPA Controller
121 or the RMC 124 can also depend from previous information
received. Information generally received, or received in response
to the questions, can be input into the RMC system from which it
can be utilized for real time risk assessment of Risks.
[0083] Some embodiments can also include an alert list containing
names and/or terms of interest supplied to the GPA Controller 121
or RMC 124 by a subscriber or other source. Each list can be
customized and specific to a particular user, or offered as a
standard to any user. The RMC system can continually monitor data
in its database via an alert query with key word, fuzzy logic or
other search algorithms and transmit related informational data to
the interested party. In this manner, ongoing diligence can be
conducted. In the event that new information is uncovered by the
alert query, the subscriber can be immediately notified, or
notified according to a predetermined schedule. Appropriate action
can be taken according to the information uncovered.
[0084] Some embodiments can also include a GPA Controller 121 or
RMC 124 that can quantify risk due diligence by capturing and
storing a record of information received and actions taken relating
to a Financial Transaction. Once quantified, the due diligence data
can be utilized for presentation, as appropriate, to regulatory
bodies, shareholders, news media and/or other interested parties,
such presentation may be useful to mitigate adverse effects
relating to a problematic transaction. The data can demonstrate
that corporate governance is being addressed through tangible risk
management processes.
[0085] In some embodiments the RMC 124 can contain only information
collected from publicly-available sources relevant for the
detection and prevention of money laundering, fraud, corrupt
practices, organized crime, activities subject to governmental
sanctions or embargoes, or other similar activities that are the
subject of national and/or global regulation. A user can use the
database to identify the possibility that a given geo-political
area or user is involved in such illegal activities and to monitor
their transactions for indications of any activities involving such
high Risk areas or persons.
[0086] Some embodiments can additionally include a funds transfer
provider 107, a transaction system 123 a user device 122 or other
device involved in geo-political area Risk Management generating a
Suspicious activity Report 109, in compliance with government
regulations.
Methods
[0087] Referring now to FIG. 2A, a flow diagram illustrates
exemplary steps that can be implemented while practicing some
embodiments of the present invention. At 202, one or more
geo-political areas can be defined in the GPA Controller 121. The
geo-political areas can be defined for example by creation of a
data base listing each geo-political area and a description of each
geo-political area. Each description can contain data that is
appropriate for the type of geo-political area defined. For
example, a political boundary maybe described according to
internationally accepted borders, while a more local geo-political
boundary may be defined according to postal code delineation or
geographic delineation. At 203, data descriptive of informational
artifacts with content related to one or more Risks can be received
into the GPA Controller 121. The data descriptive of the
informational artifact can include, for example, content of the
artifact, a source of the artifact, a date and time of publication,
a place of publication, any languages the artifact was made
available in, where the artifact can be currently accessed, past
credibility of artifacts originating from the source, or other
details. At 204, one or more of the informational artifacts can be
associated with one or more of the defined geo-political areas.
Association can be accomplished, for example with well known data
processing techniques for relating data, database search
techniques, artificial intelligence, data enhancement, data
scrubbing and other techniques known in the arts.
[0088] At 205, the GPA Controller 121 can receive data descriptive
of details of a Financial Transaction. The data can include at
least a description of one or more geographic areas associated with
the Financial Transaction. Association with the transaction can be
based upon the geo-political area of origination, the destination
geo-political area, any intermediary geo-political areas, any
geo-political areas to related to an originator 103, a recipient
104, a beneficiary, or other person or entity related to the
Financial Transaction.
[0089] At 206, the GPA Controller 121 can associate the
geo-political area with one or more artifacts that include data
descriptive of one or more Risks. Association of the geo-political
area with the data descriptive of risk variables can be
accomplished using database search techniques, artificial
intelligence, data enhancement, data scrubbing and other techniques
known in the arts.
[0090] At 207, a report can be generated with data relating to the
Financial Transaction, the geo-political areas involved. In various
embodiments, the report can include other data, such as, for
example, a risk quotient associated with the Financial Transaction
and based at least partially upon the geo-political areas involved,
data descriptive of the informational artifacts related to one or
more of the geo-political areas associated with the Financial
Transaction, an indication of an amount of risk, an indication for
a course of action, or other data.
[0091] Referring now to FIG. 2B, additional exemplary steps that
can be implemented in some embodiments of the present invention are
illustrated. At 212, a communication can be received that includes
a description of a geo-political area, such as a national
jurisdiction, a postal code, local jurisdiction, street address or
other indication of a geo-political area. The communication can
include, for example, an electronic message transmitted via an
electronic communications network, such as a computer network.
Embodiments can include a communication that is generated, for
example, as part of a data processing routine that processes data
for some business objective. For example, incident to a funds
transfer, a system that is utilized to effect a Financial
Transaction that includes the transfer of funds can also execute an
automated process that transmits an electronic communication to a
GPA Controller 121. Other embodiments can include a communication
that originates from direct user input, such as, for example, via
input into a GUI, or via an e-mail message.
[0092] At 214, the GPA Controller 121 can determine if the GPA
Controller 121 can associate a Person with the geo-political area,
such as a street address. Some embodiments can include the GPA
Controller 121 utilizing a RMC inquiry to associate a person with a
geo-political area, such as a street address. Association with a
geo-political area can include any record or artifact that links
the person with the location, for example, an land owner, a tenant,
a utility account, telephone account, a financial account, a tax
bill, a drivers license address, tax rolls, employment records,
credit card records, passport records, draft registration records,
insurance records, law enforcement records, court records,
Immigration and Naturalization Services records, other government
records, retail or wholesale shipping records, school registration
records, online (Internet) service registration, health services
records, Post Office records, news story, news article, or any
other data or artifact that can associate a Person with a
particular address or geo-political area.
[0093] At 216, the GPA Controller 121 can determine if the GPA
Controller 121 is programmed with a policy regarding any of the
geo-political areas contained in the communication of step 212. If
a policy does exist for one or more geo-political areas, then the
GPA Controller 121 can notify a user at 220.
[0094] At 218, a risk management clearinghouse search can be
conducted to search for artifacts that may contain information
indicative of an amount of risk associated with the geo-political
area, a person associated with the geo-political area, or both.
[0095] For example, a geo-political area may include a street
address, and a utility account to supply electricity to a
particular street address may include one or more account holder
names. A RMC 124 search can be conducted that searches for
information and artifacts that are associated with the street
address and the account holder names. Any information or artifacts
that are uncovered by the RMC 124 search may be useful in assessing
an amount of risk that might be associated with the account holder
names and therefore with the geo-political area that includes the
street address.
[0096] At 224, the GPA Controller 121 can generate a quantitative
value that is indicative of an amount of risk associated with the
geo-political area. For example, in some embodiments, a
quantitative value can include a risk quotient based upon risk
variables identified in an artifact discovered during the risk
management clearinghouse search. The risk quotient can be
calculated, for example, by assigning a weight to a particular risk
variable and determining a numeric measure of risk associated with
an actual value ascertained for the risk variable. In other
embodiments, a quantitative value may simply include a level of due
diligence that should be conducted regarding a particular account
or Financial Transaction, or even that a particular Financial
Transaction should be avoided until certain issues identified by
the GPA Controller 121 policy indicator or the RMC 124 search have
been resolved.
[0097] At 226, the GPA Controller 121 can transmit data conveying
the results of the previous steps 212-222. The data can include a
report with such results, including, in some embodiments an
indication of an amount of Risk associated with the geo-political
area, an amount of Risk associated with a particular Financial
Transaction, artifacts returned by a RMC 124 search, a policy
associated with a particular geo-political area, a risk quotient,
an image of any artifacts associated with the geo-political area,
values for one or more risk variables associated with the
geo-political area, names of persons associated with the geographic
address, or other data.
[0098] Referring now to FIG. 2C, additional steps that can be taken
to implement various embodiments of the present invention are
illustrated. At 230, a GPA Controller 121 can receive details of a
Financial Transaction that, in some embodiments can include fund
transfer origination information including an indication of a
origination geo-political area. At 231, the GPA Controller 121 can
receive destination information including an indication of a
destination geo-political area. In some cases, if appropriate, the
GPA Controller 121 can also receive an indication of any
intermediate geo-political areas. As discussed above, the GPA
Controller 121 will typically receive the information from a
transaction system 123, although the GPA Controller 121 may also
receive them directly from a user device 122.
[0099] At 232, the GPA Controller 121, or in some embodiments, the
transaction system 123, can transmit, or otherwise convey, related
geo-political areas, including, for example, the origination and
destination countries to the RMC 124. In some embodiments the RMC
system can provide an alert upon receipt of any new RMC system data
relating to a previously screened geo-political area or other risk
subject. Different embodiments can also include information in the
RMC system being accessed in various ways, such as, for example:
system to system inquires involving single or batch screening
requests, individual inquiries (submitted electronically, by
facsimile, or by phone) for smaller screening requests, or through
a web-based interface supporting an individual look-up service.
[0100] At 233, RMC 124 search data can be received. Embodiments can
include receiving the RMC 124 search data into the transaction
system 123 or the GPA Controller 121. At 234 and 235, direction can
be generated related to a Financial Transaction, such as a fund
transfer. For example, at 234 the direction can include an
indication of approval for the fund transferred at 235 the
direction can include a denial of the fund transfer. The
indications can be based upon a quantitative Risk evaluation, such
as for example, a risk quotient, or a policy related to
geo-political area. As such, the direction can be generated by the
transaction system 123 or the GPA Controller 121.
[0101] Referring now to FIG. 2D, basic steps are illustrated that
can be performed to implement some embodiments of the present
invention. At 240, a GPA Controller 121 can receive information
descriptive of details of a Financial Transaction, such as, for
example, a wire transfer of funds. At 241, the GPA Controller 121
can search related geo-political areas, such as, for example,
origination, intermediate and destination jurisdictions. At 242 the
GPA Controller 121 can determine if there are any predetermined
policies related to the related geo-political areas, and at 243 the
GPA Controller 121 can transmit, or otherwise convey a related
policy to an appropriate destination, such as, for example a
transaction system 123 or a user device 122.
[0102] Obviously other steps can also be incorporated into process
implementing the present invention. For example, a user device 122
or a transaction system 123 can receive an indication of how to
proceed in response to submitting details relating to a particular
Financial Transaction, such as, for example,) proceed with the
financial transaction, b) proceed with the financial transaction
and gather additional information regarding the entities involved;
c) do not proceed with the financial transaction until notified
pending gathering of additional information; and d) do not proceed
with the financial transaction.
Systems
[0103] Referring now to FIG. 3, a network diagram illustrating some
embodiments of the present invention is shown 300. An automated GPA
Controller 121 can include a computerized server accessible via a
distributed network 301 such as the Internet, or a private network.
An automated transaction processing system 123 can also include a
computerized server accessible via the distributed network 301. A
user can use a computerized system or network access device 122 to
receive, input, transmit or view information processed in the GPA
Controller 121, transaction processing system 123, a peer device,
or other network access device 122. A protocol, such as, for
example, the transmission control protocol internet protocol
(TCP/IP) can be utilized to provide consistency and
reliability.
[0104] A system access device 122 can communicate with the GPA
Controller 121 or transaction processing system 123 to access data
and programs stored at the respective servers. A system access
device 122 may interact with the GPA Controller 121 or transaction
processing system 123 as if the servers were a single entity in the
network 300. However, the GPA Controller 121 and transaction
processing system 123 may include multiple processing and database
sub-systems, such as cooperative or redundant processing and/or
database servers that can be geographically dispersed throughout
the network 300.
[0105] A server utilized in a transaction processing system 123 and
GPA Controller 121 can include a processor, memory and a user input
device, such as a keyboard and/or mouse, and a user output device,
such as a display screen and/or printer, as further detailed in
FIG. 4. Any server can also include one or more databases (700, 800
in FIG. 4), storing data relating to a geo-political area, a
Financial transaction, transaction participant, informational
artifact, associated risks, or other pertinent information.
Information relating to and included in geo-political related risk
management can be aggregated into a searchable data storage
structure. Gathering data into an aggregate data structure 700,
800, such as a data warehouse, allows a server 123, 314 to have the
data readily available for processing a risk management search
associated with a Financial Transaction. Aggregated data 108, 304
can also be scrubbed or otherwise enhanced to aid in searching.
[0106] Typically, an access device 122 will access a GPA Controller
121 using client software executed at the system access device 122.
The client software may include a generic hypertext markup language
(HTML) browser, such as Netscape Navigator or Microsoft Internet
Explorer, (a "WEB browser"). The client software may also be a
proprietary browser, and/or other host access software. In some
cases, an executable program, such as a Java.TM. program, may be
downloaded from a server to the system access device 122 and
executed at the system access device 122 as part of a GPA
Controller 121. Other implementations include proprietary software
installed from a computer readable medium, such as a CD ROM. The
invention may therefore be implemented in digital electronic
circuitry, computer hardware, firmware, software, or in
combinations of the above. Apparatus of the invention may therefore
be implemented in a computer program product tangibly embodied in a
machine-readable storage device for execution by a programmable
processor and method steps of the invention may be performed by a
programmable processor executing a program of instructions to
perform functions of the invention by operating on input data and
generating output.
[0107] In some embodiments, data contained in a database can be
scrubbed or otherwise enhanced. Data scrubbing can be utilized to
store information in a manner that gives efficient access to
pertinent data and facilitate expedient access to data.
Controller
[0108] FIG. 4 illustrates a controller 400 that can be descriptive
of a computer that can be utilized as a server or access device
121-123 shown, for example, in FIG. 3, according to some
embodiments of the present invention. The GPA Controller 121
comprises a processor 410, such as one or more processors, coupled
to a communication device 420 configured to communicate via a
communication network (not shown in FIG. 4). The communication
device 420 may be used to communicate, for example, with one or
more network access devices 122.
[0109] The processor 410 is also in communication with a storage
device 430. The storage device 430 may comprise any appropriate
information storage device, including combinations of magnetic
storage devices (e.g., magnetic tape and hard disk drives), optical
storage devices, and/or semiconductor memory devices such as Random
Access Memory (RAM) devices and Read Only Memory (ROM) devices.
[0110] The storage device 430 can store a program 430 for
controlling the processor 410. The processor 410 performs
instructions of the program 430, and thereby operates in accordance
with the present invention. For example, the processor 410 may
receive information descriptive of geopolitical areas and associate
those areas with predefined policies and/or transmit the
information to an RMC.
[0111] The storage device 430 can store geo-political risk
management related data in a database 700, and other data 800 as
needed. The illustration and accompanying description of the
database presented herein is exemplary, and any number of other
database arrangements can be employed besides those suggested by
the figures.
User Interfaces
[0112] FIGS. 5-6 illustrate aspects of some embodiments of user
interfaces. Referring now to FIG. 5, an interface can be utilized
in some embodiments relating to wire transfer can include
interactive areas for inputting, displaying and editing data
representative of: a transaction participant name 510, a
transaction participant address or other indication of a
geo-political area or designation associated with the transaction
participant 511, a beneficiary 512, a tax identification number
513, a type of identification document associated with the
transaction 514, a country of issuance of an identification
document 515, an originator citizenship 516, a recipient or
beneficiary citizenship 517, origination geo-political area 518,
intermediary geo-political area 519, destination geo-political area
520, or other related data 521.
[0113] Referring now to FIG. 6, an interactive graphical user
interface is illustrated, which can accommodate those features
described in FIG. 5 or additional functionality, such as, for
example, an area to input one or more geo-political areas 602, one
more policies related to each geo-political area 603, a threshold
risk quotients that may trigger a suggested action 604 and an area
for receiving instructions that can be conveyed and which relate to
one or more particular geo-political areas 601.
[0114] Geographic Address Information Database
[0115] Referring to FIG. 7, a table represents the geo-political
area information database 700 that may be stored in conjunction
with a controller 500 according to some embodiments of the present
invention. The table includes entries identifying geographic
locations or other geo-political areas to which communications may
be facilitated 702. The table also defines a artifact information
704, a source 706 for each of the entries and a participant name
708. The information in the geo-political area information database
700 may be created and updated, for example, by the controller 600
and/or a third-party service (e.g., an RMC service provider).
[0116] Risk Management Database
[0117] Referring to FIG. 8, a table represents the risk management
database 800 that may be stored at a controller 500 according to an
embodiment of the present invention. The table includes one or more
entries identifying requests that have been received and/or
processed by the controller 500. The table also defines fields 802,
804, 806, 808 for each of the entries. The fields specify: a
government list 802, a media publication 804, a geographic address
806, and a transaction participant name 808. The information in the
risk management database 800 may be created and updated, for
example, as the controller 600 receives information.
[0118] Other information may be stored in the risk management
database 800 in addition to the information illustrated in FIG. 8.
For example, the risk management database 800 may indicate a date,
a time, and/or a location associated with risk management (e.g., a
time period during which a high risk individual was associated with
a geographic address) and/or a reason why a particular geographic
address was associated with a high risk (e.g., indicating a list or
other source indicating a risk associated with an individual.
ADDITIONAL EMBODIMENTS
[0119] Although many of the embodiments described herein are
associated with a controller 500 facilitating communications,
according to another embodiment communication devices instead
communicate with each other to perform this function (e.g., a group
communication devices may utilize peer-to-peer communications to
facilitate communications via destination identifiers).
[0120] Moreover, the embodiments described herein are associated
with a controller 500 performing a number of functions. According
to other embodiments, some or all of these functions can instead be
performed by any of the other devices described herein. For
example, a communication device or a user device may perform some
or all of the functions described with respect to the controller
500.
[0121] The present invention has been described in terms of several
embodiments solely for the purpose of illustration. Persons skilled
in the art will recognize from this description that the invention
is not limited to the embodiments described, but may be practiced
with modifications and alterations limited only by the spirit and
scope of the appended claims. Further, although the foregoing
embodiments were described for clarity, those skilled in the art
will understand how to make any changes, if necessary, to the
above-described apparatus and methods to accommodate these and
other embodiments and applications.
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