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Sentinel assesses the risk of an account holder participating in money laundering, fraud and criminal acts. The account holder, here after referred to as 'the applicant', is checked against a set of government and private data sources. A list of the data sources can be found by clicking on the Help -> Data Sources menu item. Identifying information about the applicant is compared against these data sources to determine if the Applicant poses a high risk of being involved in fraud, crime or terrorism. A risk level is then assigned for each data source check. Details about why an applicant received a particular risk level are available in Matching Rules.
For certain data sources and users when a customer is screened before a risk status is assigned Sentinel compares the new customer results to old screens run by the same user to see if a new, duplicate or new data match occurs, see Appendix A for a list of risk levels. The comparison is based on a user's preference to have the "New Data Alert" enabled, the customer account number, the unique ID of the source data and the last update date if available. See New Data Alert for a list of data sources that use the New Data risk level and how the comparison is performed.
When an applicant is screened each available data source is assigned a Risk Result. The result is based on the data entered and on whether a user has chosen to use the "New Data Alert" function of Sentinel. See Risk Results for a list of all available risk levels. Risk levels are also prioritized and categorized. The highest risk level is first in all risk drop downs and aggregated reporting.
|Risk Found, Needs Review:||Result Type 100 - 199|
|Risk Found and Reviewed:||Result Type 200 - 299|
|No Risk Found:||Result Type 300 - 399|
The applicant check process is initiated by logging into Sentinel and clicking the Applicant Checks -> New Account menu item. This will bring up the Applicant Information screen. All data regarding an applicant should be entered into this screen. Required items are marked with a red asterisk (*). If a piece of information is required but not available enter 'n/a' in the required field. Click the Submit button when all data is entered.
Different types of Applicant data are collected: Personal Information (including address, ID type and number), company information, account information (an optional internal banking account number used to tie the check back to bank's internal account).
If no employer information is available check the 'No company data available' check box. This will allow you to skip the company information section.
Figure 6: Applicant Check Screen
The Patriot Act requires that financial institutions record what identifying documentation was used to open an account. This information is recorded in the 'Identification Information' section. For instance if an applicant used a Virginia drivers license as identification to open an account you would choose 'Drivers License' from the 'ID Type' drop down. You would put 'Virginia' in the 'Issued by' text box and then enter the driver's license id number in the 'ID Value' text box.
Applicant Check Results
The Applicant Check Results page lists each data source check and the associated risk level High, Medium, Low, or No Match Found.
Figure 7: Applicant Check Results Screen
The data source question is listed on the left of the Applicant Results screen and the associated risk is listed on the right. Clicking on the data source question (on the left) will open a help file with details about how a data source works and what data is checked. Clicking on the associated risk (on the right) will bring up the Applicant Check Details screen. The Applicant Check Details screen lists what data was used to formulate the associated risk level for that particular data source.
Data source checks fall into two broad categories, watch lists and identity verification. Watch lists are negative checks. Watch lists check to be sure that applicant data does not match records in a data source. An example of a negative match data source is the OFAC data source. A match against the OFAC list indicates that an applicant may be involved in terrorism or drug trafficking. A low risk results from no match being found, therefore 'No match found' will be displayed as the result of this check.
Identity verification checks have both positive checks, where a match means that there is a low risk, and negative checks. Because both positive and negative checks exist for Identity Verification data sources all row risk checks are displayed as 'Low Risk'.
Applicant Check Details
Each applicant check detail screen contains five types of data, the data source name, the Result Type which indicates the risk level for the data source, the search type (Person, Entity, Address, etc), score and the records in the data source that the applicant matched against.
Data source checks fall into two broad categories, positive and negative checks. Positive checks are data sources where the applicant data is supposed to be found in the data source. A match indicates that the data source is low risk. An example of a positive data source is the Postal Service zip4 data source. The zip4 data source contains all the valid mailing address in the US. An applicant address match against the zip4 data source indicates that the address is valid. A match for a positive check data source means the data source is 'Low Rick' and the data source details will display the data that was matched against.
If there is no data match then the data source is high risk.
Negative match data sources check to be sure that applicant data does not match a data source. An example of a negative match data source is the OFAC data source. A match against the OFAC list indicates that an applicant may be involved in terrorism or drug trafficking. A 'Low Risk' results from no match being found, therefore 'No Match Expected', 'No match found' will be displayed.
A 'High Risk' result would list the data that was matched against.
Figure 7a: Applicant Check Details Screen