This the inaugural post for my "Questions I wish you would ask your data service" Series. #Definitions "Can you explain what that means?" “How did you define X when the legal meanings vary across jurisdictions?” Labels mean different things to different people and typically don't tell me what is in that specific data bucket. ?? Apples are mixed with ?? oranges and sometimes ?? grapes are thrown in too because 'hey it's data and more is better!' But that introduces ambiguity, skews results, and in some places means that the data cannot be collected or used for certain purposes (e.g. in the EU there’s no legal basis for reputational data collection, but there is for AML/CFT.) ??Fruit basket data is a problem for #AI or #risk models in #AML #CFT #sanctions and a problem for #dataprotection - also focused on accuracy for many of the same reasons as #financialcrime - to protect individuals. Determine the goal and the use case. Identify and define the data needed to achieve it. Research. ·????????International organizations are not non-governmental organizations. ·????????Bank Fraud is not Wire Fraud, nor is it Mortgage Fraud. ·????????Bribery and Corruption are related, but there are distinct differences. ·????????Organized Crime is not Terrorism. These groups use similar methods of violence and coercion, but for different reasons. Without clear definitions can you identify what data should be collected for the goal? How do you know if that data is fit for purpose? How can you determine data quality if you haven’t defined the standards? You can't. Clear definitions are a foundation of good data methodology that shows regulators and your clients (if you are a data vendor) why you chose that data and how you got there. Document it. Process is important. You need subject matter experts, not just data scientists, to tell you how the world works so your data reflects reality. Yes, we are a diverse world of cultures, ideas, government systems, laws etc.?It is possible to find similarities, set inclusion and exclusion ranges, to achieve a broad standard. The definition question is hard for most to answer because they haven't thought about it. That’s a red flag. ?? I know that interoperability is an issue, and the devotion to APIs (also rarely defined) is core to #AML #CFT tech, but it's usually a profit issue. Definitions are tedious, but that’s not a good reason to ignore them. ·????????Do definitions reflect legal and regulatory considerations or are they just copy/paste without context? ·????????If the response is “it’s FATF” that’s not good enough.?Execution of the Recommendations involves interpretation.?What’s their interpretation and how did they arrive at it? ·????????Do international organization or industry standards exist and if so how have they been integrated? ·????????What jurisdictional discrepancies did you find and how did you handle them? Want to learn more??DM to schedule a consultation. Frasher Risk Advisory LLC
Frasher Risk Advisory LLC
商务咨询服务
Philadelphia,PA 20 位关注者
Boutique consultancy helping clients navigate complex financial crime, data privacy, and geopolitical risks.
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Dr. Michelle Frasher, PhD, CAMS is a trusted advisor helping early-stage startups and large organizations navigate complex risk with over 20 years’ experience and subject matter expertise in AML,CFT, data privacy, geopolitics, and finance. Our logo represents risk as an inter-woven tapestry of actors, events, and interests. Key Services AML/CFT and Data Privacy and Protection (DPP) ? DPP and AML/CFT national and cross-border regulatory analysis ? Operationalizing DPP in compliance workflows ? Data sharing networks (314a/b, PPPs, private-private, enterprise) ? Data strategy and governance ? Data Subject Access Requests (DSAR), DPIAs, and privacy program management Strategic Advisory ? Business Strategy in Regulated Industries ? Compliance for Startups ? Stakeholder Mapping, Partner Identification and Engagement ? Keynote Speaking and Subject Matter Briefings Geopolitical Risk and Regulatory Analysis ? Sanctions, UBO, supply chain, dual use goods ? Political, Regulatory, and Legislative Analysis and Engagement Strategies Strengthening Organizational Capabilities ? Training: Sanctions, AML/CFT, and Research Methods, Critical Thinking and Writing ? Risk Management for Boards and Senior Officers ? Product Strategy: Regulation to roadmaps, GTM and Sales alignment ? TPRM: AML Data and Technology providers ? Policies and Process Assessment and Improvement Also providing expert research on specific questions or issues. Message to schedule a 30 minute consultation and for service pricing.
- 所属行业
- 商务咨询服务
- 规模
- 1 人
- 总部
- Philadelphia,PA
- 类型
- 自有
- 创立
- 2023
- 领域
- data privacy、AML、CFT、Sanctions、Data、GDPR、data sharing、public private partnerships、compliance、KYC、screening、geopolitics、risk management、AI data modeling、BSA、AMLD、cross functional leadership、data quality、OFAC、Regulatory Analysis和beneficial ownership
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Frasher Risk Advisory LLC员工
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As some of you may have noticed, my LinkedIn banner changed in the fall to a "woven F" to reflect my venture to consulting at Frasher Risk Advisory LLC. I am grateful for the support of my network and excited to announce that I've been working with some fantastic organizations on #AML #CFT #dataprivacy #datasharing #fraud #UBO #data #sanctions #GTM #productdevelopment If you're interested in improving your compliance processes or business, please visit and follow Frasher Risk Advisory LLC's page for a full menu of services, including strategic advisory, geopolitical risk and regulatory analysis, strengthening organizational capabilities, and expert research on specific questions or issues. #AML #CFT #DataPrivacy #Protection #GeopoliticalRisk #RegulatoryAnalysis #OrganizationalCapabilities #ExpertResearch