It’s a useful way to look at, and design, your business processes and workflows for reviewing potential matches to watchlists, really.
From left to right, you have a number of workflows, segregated out by the ways it makes sense for you to run your business. There are a lot of ways you might do this, all depending on how you organize yourself, volumes and the complexity of what you do:
- Geographic breakdowns, especially if you operate in multiple regulatory jurisdictions.
- Organizational breakdowns. These could be segregation by divisional lines (e.g. like a Bank Holding Company with multiple financial service firms), or by functional lines (Human Resources vs. Static Data Management)
- Breakdown by type of data screened. You might want to separate insurance claims from policy information, for example
- Breakdown by types of screening performed, or watchlists used. If there are daily screens of new accounts as well as periodic screens (e.g. weekly or monthly), it might be useful to put the results in separate workflows. Similarly, matches against sanctions lists might be segregated from non-sanctions lists (especially the PEP list), either because of the differences in match volumes, or because the underlying handling of true matches can be very different.
One of the niceties about not just lumping all your screening into one big workflow is that allows you to have variability in how things are processed. Certain areas may require additional levels of review, or may require different processing due to different staff capabilities and experience, or organizational reporting lines.
The vertical direction of the workflow rectangle are the process steps you wish to capture in workflow, from the initial stop for review to final resolution. Common (although not necessarily advisable) intermediary steps include:
- Setting aside items for more research. One consideration is that, if multiple levels of staff can do this, your system needs to have a mechanism for keeping them separate.
- Escalating an item to a higher level of staff
- Referring an item back to a lower level of staff for more research to be conducted
Mr. Watchlist’s personal preference is to define a simple workflow structure and, if necessary, make it more complex over time. A sign of a poorly-designed workflow is when parts of the workflow are infrequently used with any sort of volume. For example, if you account screening can be routed to 10 work folders or queues (in a structure not defined by organizational boundaries) and each one ends up with a small handful of items on any given day, it would make sense to redesign the workflow to have fewer buckets to put your matches into. Similarly, if you have 6 levels of escalation, and the top 3 are used once or twice a year, perhaps those should be handled by email, not within a system where the staff member will require a password reset each time they access the system.
I will deal with the third item in the list above in a separate post, because … well, just because.