=Paper=
{{Paper
|id=Vol-1981/paper1
|storemode=property
|title=Survey of Common Design Approaches in AML Software Development
|pdfUrl=https://ceur-ws.org/Vol-1981/paper1.pdf
|volume=Vol-1981
|authors=Alexander Semenov,Artem Mazeev,Dmitry Doropheev,Timur Yusubaliev
}}
==Survey of Common Design Approaches in AML Software Development==
Survey of Common Design Approaches in AML Software Development Alexander Semenov Artem Mazeev JSC NICEVT JSC NICEVT Moscow, Russia Moscow Institute of Physics and Technology alxdr.semenov@gmail.com Moscow, Russia mav367@mail.ru Dmitry Doropheev Timur Yusubaliev Moscow Institute of Physics and Technology Quality Software Solutions ltd Moscow, Russia Moscow, Russia dmitry@dorofeev.su ytr@kpr-it.com Abstract The role of financial institutions is to find ways to identify, among the huge number of operations that oc- In the recent years, money laundering activ- cur every day, those suspicious transactions and then ity has become more and more ubiquitious investigate them in more detail [3]. There are many all over the world. In the paper we survey illegal money laundering schemes of complex nature, the technical aspects of anti-money laundering and new sophisticated schemes appear exploiting ever systems (AML). We briefly present the prin- increasing richness of money forms and economic ac- ciples of money laundering process and fea- tivity [4]. Some schemes are recognized by FATF (Fi- tures of the illegal activity that can arise in the nancial Action Task Force inter-governmental organi- graph of money transactions, company or user zation that aims to set standards and promote effective profiles. Then we present a detailed analysis implementation of legal, regulatory and operational of anomaly detection, machine learning and measures for combating money laundering, terrorist neural networks techniques in the context of financing and other related threats to the integrity of AML systems. the international financial system [5]). Keywords: anti-money laundering, machine There are a large number of papers that consider learning, anomaly detection, graph mining the solution of this problem, but most of them be- long to authors from China [6], Australia, India [7], Sweden, [8], Poland, Ireland [9], Egypt [10], Pakistan 1 Introduction [11], Saudia. IT Giants and authors from the most Money laundering (ML) is a criminal activity or pro- advanced natures do not publish papers which con- cess that deals with criminal proceeds to disguise their tain technical considerations of anti-money laundering illegal origin and make them appear legitimate. In (AML) systems with corresponding keywords. recent years, money laundering activity is becoming There exist only small number of survey articles more and more ubiquitious all over the world [1]. Be- on AML systems and algorithms [12, 13, 14]. Related tween 1.5 trillion USD and 2.8 trillion USD or between works are cited in [11,15,16,17] and some other papers. 2% and 5% of global gross domestic product (GDP) is Besides money laundering there is another type of lost annually through money laundering worldwide [2]. illegal activity. Fraud is a crime where the objective is to gain money by an illegal form [18]. Fraud detection Copyright c by the paper’s authors. Copying permitted for is similar to money laundering but our survey considers private and academic purposes. only money laundering. In: V. Voevodin, A. Simonov (eds.): Proceedings of the GraphHPC-2017 Conference, Moscow State University, Russia, The survey is an introduction to technical and cor- 02-03-2017, published at http://ceur-ws.org. responding aspects of anti-money laundering systems. 1 The organization of the survey is as follows. Sec- However, there are also two-stage and four-stage tion 2 deals with principles of money laundering pro- models [20]. In the four-stage model placement oc- cess and features of the illegal activity that can be curs simultaneously in many places (small amounts for found in the graph of money transactions, company many different accounts, often through acquaintances, or user profiles. Section 3 provides a historical re- relatives). view of main anti-money laundering approaches. Sec- The financing of terrorism differs from money laun- tion 4 presents detailed analysis of the state-of-the-art dering in that the funding sources can be of legal ori- techniques and AML systems. Finally, we conclude in gin. Section 5 . It is clear from the three-stage model that a typical money laundering scheme involves multiple transac- tions, conducted through a variety of different chan- 2 Money Laundering Features nels, banks, by a group of parties (individuals, busi- The process of money laundering usually consists of nesses, etc.). three stages [19]: Different schemes can be borrowed from the rules of committees that exist in different states. For ex- • Placement is a transfer of cash into financial sys- ample, in USA [21], in Australia [22]. There are also tem. Placement is carried out in credit institu- state-controlled organizations that help businesses, for tions, security markets, retail trading. The goal example in the USA — FINRA [23]. Some typical of placement is to conceal or disguise source or money laundering schemes are described in [19, 24]. ownership of the illegal funds. Often funds are Basic characteristics of a money laundering scheme placed in the foreign countries. The stage of place- are the following: a role assignment between the par- ment of criminal proceeds is the most unreliable ties, a particular execution order of the transactions, stage in the process of money laundering. At this synchronization of transactions as per time and the stage there is the best chance to identify illegally amount of transactions, etc. received funds. The authors of [25] note the following important • Layering is a separation of criminal proceeds features for AML: from their sources through complex chains of fi- nancial transactions aimed at disguising the trace • Type of the main activity of the company (retail, of the illegal funds. Various financial operations gambling, intermediary services); • Type, amount and size of transactions (cash re- overlap one another in order to complicate the ceipt, withdrawal of cash from ATM); work of AML systems and experts aimed to iden- • Geographical factor (offshore operation, partici- tifying criminal proceeds and persons who legal- pation in the transaction of the company or a ize them. If the placement of criminal funds was bank with a critically low level of AML); successful, that is, it was not discovered, then it • Specificity of the organizational structure (for ex- becomes much more difficult to detect illegal op- ample, the company with too young founders); erations at this stage. • Events preceding the transaction (changes in the • Integration is the last stage of the legalization ownership of the company, obtaining a large loan); process, directly aimed at creating the appear- • Transaction history. ance of legality to the criminally obtained capital. Funds separated in the previous stages are con- 2.1 Client Profiling solidated at the integration stage into some form, which is convenient for the customer: money on In AML it is important to determine potential risky the account in a first-class bank, liquid securities, parties (users, clients). AML systems can have an in- real property assets. The laundered funds are in- creased focus on risky users. vested further in the legal sectors of the econ- The following can be used as features of risky users omy, which also creates a basis for new crimes. [3, 26]: To simplify further legalization of funds, crimi- • Large deposits and withdrawals; nal communities acquire credit organizations and • Periodicity of transactions; other financial institutions, and also buy signifi- • Transactions in risky areas regarding money laun- cant shares in the ownership of enterprises in the dering (in free trade-industrial zones); real sector of the economy, transferring them un- • Transactions of less than a specified threshold der their own control. If the money laundering amount in order to avoid control of AML systems; trace has not been identified in the two previous • Degree of bank service usage; stages, then it is extremely difficult to separate le- • Reactivation of off-line accounts; gal funds from illegal ones at the integration stage. • Account age. 2 2.2 Graph Patterns Real graph patterns can be highly complicated. In the paper [28] an algorithm for searching of “volca- Money laundering can be detected in the graph of noes” and “black holes” patterns is proposed, which money transactions. Relations between parties in the actually represents the placement, layering and inte- graph of money transactions produce social network. gration model. Figure 4 shows these patterns. The graph mining methods and methods of social net- works analysis can be applied to detect suspicious transactions [27]. There are different patterns (templates) in the transaction graph that can be suspicious. A com- mon structure of a subgraph is in Figure 1 and can correspond to the placement, layering and integration model. Initially money is placed in X vertex. Two other typical AML subgraphs are shown in Figures 2 and 3. It refers to cyclic business activity to con- ceal money’s genesis. Of course, these examples are only schematic and real subgraphs can be different and Figure 4: ”Volcanoes” and ”black holes” in the trans- complicated. Many relevant papers solve the problem action graph. of searching of clusters in the graph by some criteria. 3 Anti-Money Laundering Principles The AML problem can be solved by using different approaches: • Rule-based approach; • Anomaly detection; • Machine learning. One of the first AML-systems [29] was created in 1995 and was based on rules. Rules can be very com- plex and can be defined with use of decision trees [30]. Rules are formulated by experts and can very accu- Figure 1: Common structure of a subgraph in the rately detect criminal schemes. However, this tech- placement, layering and integration model. nique is human dependent, not flexible and not auto- matic. Further, it can not be used to recognize new typologies of fraudulent transactions. Data mining techniques involve interdisciplinary methods from machine learning, statistics and databases. Anomaly detection [31, 32, 33] is the one of the data mining problems. Systems that use the anomaly detection began to appear after systems based on rules. The report [34] provides an overview of data mining techniques for detecting fraud in differ- ent areas. The advantages of anomaly detection are a capability of discovering new laundering patterns and Figure 2: Common structure of a subgraph represent- an ability to customize normal activities. ing illegal cyclic business activity. Machine learning and artificial intelligence are big topics in the financial services sector these days. Machine learning is increasingly used in the modern systems [15, 35]. The most popular problem is the classification problem (two-class classification). The goal is to define whether the given transaction is sus- picious or not after procedure of training on prece- Figure 3: AML subgraph pattern. dents. The test set of precedents specifies information, which transactions are suspicious and which are not. 3 The problem can be considered in terms of probabil- is to find unusual points (outliers). Outliers can be ity, when for each transaction a probability (weight) of searched using different algorithms [40], for example, transaction being suspicious is assigned. The Bayesian using the K-nearest neighbors algorithm [41]. classification methods can be used for the problem. It is also possible to use statistical methods to This type of detection is only able to detect frauds anomaly detection [31]. One needs to build distribu- similar to those which have occurred previously and tion function of some feature as a random variable, have been classified by a human. To detect a novel and then select the parameters, by which the outliers type of fraud it may require the use of an unsupervised can be detected. machine learning algorithm. Despite the absence of the training phase, it is pos- Earlier AML-systems often used the principle of sible to develop some method of determining the sus- analyzing the actions of a particular person, but in picious transactions to suggest the user, which trans- modern AML-systems, the analysis of the network (or actions may be suspicious. For example, a good simple graph) of transactions is increasingly used. For exam- idea is to use the knowledge about customers and de- ple, in [36] on the basis of bank data, a social network tect activities that are not typical for reliable clients is built between the clients of the bank, which are con- [42]. nected by transactions. The clustering based techniques group customers The papers [25, 37] consider a search of patterns that perform similar kind of transactions into a single in graphs (template subgraphs) that are most similar cluster and then categorize either small-size clusters or to the known patterns. The principle of approximate outliers as anomalous [11]. search is applied when there is no need for a fixed Theoretically, supervised anomaly detection pattern matching, which means that the search is more methods can provide better results than unsupervised flexible as it allows some deviation from the templates. methods, since they are based on more information. However, the training sets usually contain some noises 4 Modern Techniques and Systems that result in higher false alarm rates, and obtaining It is hard to strictly classify approaches to the devel- accurate training set is a difficult problem [33]. opment of AML systems. Each AML subsystem can uses different data mining techniques. 4.2 Graph Mining Many techniques have been developed in the past 4.1 Anomaly Detection decades for spotting outliers and anomalies in unstruc- Anomaly detection is an identification of elements of tured collections of multi-dimensional data points. a given dataset that do not conform to the expected On the other hand, data objects cannot always be pattern. These anomalies occur very infrequently but treated as points lying in a multi-dimensional space may signify a large and significant threat such as cyber independently [43]. Transaction graph is a good intrusions or fraud, i.e. it is necessary to detect the abstraction for data represeting in AML systems, anomaly (suspicious) data in the background of the inter-dependencies between transactions should be ac- other data. counted for during the anomaly detection process. The advantages of anomaly detection are capability In [43] a comprehensive survey of graph based of discovering new laundering patterns and customiza- anomaly detection techniques is presented. tion ability of normal activities. The anomaly detec- Graph pattern matching or graph isomorphism can tion drawback is a high rate of false alarms. be appropriate technique for searching abnormal sub- The unsupervised anomaly detection techniques graphs in the transaction graph. But exact matching do not need training data. This kind of methods is makes too strict requirements, and inexact algorithms beneficial when some abnormal behavior has not been should be used instead. For example, in the paper [28] demonstrated in the training sample, for example, if an algorithm for searching of “volcanoes” and “black the sample is small. holes” patterns is proposed, which actually represent There are a large number of methods and algo- the placement, layering and integration model. Figure rithms for anomaly detection [32], for example: clus- 4 shows these patterns. tering techniques [38], unsupervised neural network, Database information about attendees and their re- fuzzy C-means [39]. lations can be useful for anti-money laundering algo- A set of the features is necessary for algorithms of rithms. So social network analysis can be additional anomaly detection as well as for supervised learning. technique that can be used in AML systems [44]. For Note that the vector of features (numbers) can be rep- example, in [36] on the basis of bank data, a social resented as a point in n-dimensional space (where n network is built between the clients of the bank, which is the number of features). The goal of the algorithm are connected by transactions. Features are calculated 4 for each customer (betweenness centrality, page rank, 4.5.1 Australian AML system etc.). Based on the features, each client is assigned a The Australian AML system developed for the Aus- role, for example, it can be an isolator role that isolates tralian Transaction Reports and Analysis Centre a certain group of clients from the rest; Another role (AUSTRAC) [49] is described in the recent papers – the role of a communicator, which, on the contrary, [15, 50] in 2016, 2017. connects several groups of customers. Further analy- sis of new transactions checks whether the previously The system analyzes two types of transactions: identified role of the client is consistent with its new large cash deposits and oversea transfers. The sub- behavior. ject of the analysis is a graph in which parties are con- nected by edges of two types: one type for transaction, 4.3 Fuzzy Graph Patterns another type for suspicious relations between parties. There can be a lot of suspicious relation cases, for ex- In modern AML systems, the search of subgraphs that ample, two persons own the same account. Transac- approximately satisfy the given criteria is an impor- tion edge has a weight. tant component. The problem is called fuzzy graph The system performs the following actions: isomorphism. In [25] authors present an algorithm for finding a fuzzy set of maximal cliques, they claim that 1. Modeling of relationships between parties using a method based on the algorithm can contribute to mod- graph with attributes; ern AML systems that use comprehensive information from various information sources about actors as well 2. Community extraction from the transaction as experts evaluation. graph; In [37] authors propose a method for mining tran- scation graphs based on building a model that is 3. Calculation of the features from the extracted parametrized by fuzzy numbers. These numbers repre- communities; sent parameters of transactions and of the transaction subgraphs to be detected. The method uses genetic 4. Supervised learning. algorithm for parameters optimization. Fig. 5 shows the general scheme of the system. 4.4 Client Profiling Systems It has been noted that in AML systems it is important to determine potential risky parties (users, clients). In [3] a client profiling subsystem is proposed. All bank clients are clusterized with use of k-means [45] and other algorithms by some features. Unsupervised anomaly detection techniques are used for discover- ing new patterns with subsequent rule generation al- gorithm [46]. In [26] fuzzy rules are used for description genera- tion of risky users. Fuzzy rules retain the advantages of fuzzy expert systems, while reducing the need for an expert. The 5-layered neural network trains and im- proves the fuzzy rules. The training method includes a combination of least squares and back propagation. 4.5 Machine Learning In recent years, machine learning and artificial intel- Figure 5: Scheme of the Australian AML system. ligence have seen an increasing interest and popular- ity in the financial services community [15, 37, 47, 48]. Machine learning is a particularly powerful tool for The development of algorithms for community de- prediction purposes. Supervised methods (also known tection in a graph with attributes is an important sci- as classification methods) required a labeled training entific challenge. There are only limited number of set containing both normal and anomalous samples to concerned papers, for example, the preprint of the pa- construct the predictive model. per [51]. The existing community detection algorithms AML system based on machine learning principles can be poorly adapted to a specific task, for example, is described in the next subsection 4.5.1 . they detect communities of too large size. At the same 5 time, in the problem of detection of suspicious transac- method has the highest detection rate and the lowest tions the size of the criminal communities are relatively false positive rate. small. In [26] a 5-layered neural network trains and im- The k-step neighbors algorithm is used to commu- proves the fuzzy rules, which are used for generation of nity extraction in the considered system. Authors use risky users description. The training method includes its own methodology for processing the communities a combination of least squares and back propagation. that can overlap. Algorithms of the classification problem in machine 5 Conclusion learning need a set of formalized features of each ob- ject. In the considered system different features are In the paper we survey the technical aspects of anti- calculated for the extracted communities. Features are money laundering systems. We briefly present the determined by experts (unpublished, closed part of the principles of money laundering process and features of paper). Authors note that features can be divided into illegal activity that can arise in the graph of money several categories: transactions, company or user profiles. Then we present a detailed analysis of anomaly detection, ma- 1. Demography. Aggregated features that describe chine learning and neural networks techniques, and the persons in the graph, for example, the average modern Australian AML system. age; Research is being conducted with the finance sup- port of the Ministry of Education and Science of the 2. Graph. Features that describe the structure of Russian Federation Unique ID for Applied Scientific the graph; Research (project) RFMEFI57816X0218. 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