Categories: Data Analytics

In response to an action taken by the Federal Reserve Bank of New York and the New York State Department of Financial Services, provided investigation, financial analytical and project management resources to one of the first-ever "transaction lookbacks" performed in connection with a bank regulatory action related to the institution's systemic failures to detect and report suspicious activity.  The project consisted of an exhaustive review of U.S. based transactions spanning multiple years seeking to identify and report previously unreported suspicious activity.  The project enabled the bank to avoid severe penalties and restrictions being imposed on the bank and led to widespread improvements to the bank's transaction monitoring, investigation and suspicious activity reporting processes.

A major mutual fund company was concerned that they did not have complete visibility into what extent their various mutual fund investments included state-owned companies and/or investments in industries or entities with operations that were subject to U.S. Department of Treasury restrictions as enforced by the Office of Foreign Assets Control.  The team worked with a vendor that specialized in public company data aggregation and was able to query their entire repository of publicly traded companies on each stock exchange in the world and batch process the entire list against OFAC's various restrictive trading lists and a proprietary list of state-owned companies.   The results of this intensive batch processing exercise provided the Chief Compliance Officer with critical information about the state of the company's OFAC and Foreign Corrupt Practices Act compliance programsand enabled him to strengthen those compliance programs based upon what was learned.

A WCF executive had a leadership role in one of the largest data analytics investigations ever conducted. A major technology company which makes apps available to its customers via its platform performed a large-scale investigation of how app developers using its platform utilized customer data. An initial review of app developer behavior centered on the number of users, the volume of data being consumed by those users and the apps potential for abuse. A subset of those developers were then subject to a more intensive technical analysis of their activity on the platform. This signal analysis then led to certain developers being subjected to more rigorous technical reviews, the requirement that they complete in-depth questionnaires, and be subjected to public record background investigations. Given the high public profile of the investigation, the company and its outside counsel used the results of the data analysis and background investigations to provide updates to the public, its customers, regulators and law enforcement agencies and provided ultimately enabled the company to enter into settlements with consumer protection and regulatory agencies.

In connection with a Securities Investor Protection Corporation liquidation matter, a WCF executive oversaw the analysis and disposition of assets belonging to the broker dealer and its executives who were involved in insider trading and a series of pump and dump schemes. The team used data analytics to analyze over 10 million outbound phone calls in an effort to identify assets recoverable to the trustee who could then return assets to victims. The phone records analysis revealed that hundreds of calls were placed to banks, law and accounting firms located in several offshore, money laundering safe haven countries enabling the investigative team to identify financial institutions where some of the proceeds of the fraud had been transferred. This effort enabled the trustee to pursue the repatriation of those assets through Mutual Legal Assistance Treaty requests and letters rogatory procedures.