Anti-witwassen

HEMOLIA, Europees anti-witwas- en anti-terrorisme-financieringsproject.

Switchlegal is één van de partners in een Europees anti-witwas project, HEMOLIA genaamd. Dit project is gericht op het beter analyseren van verschillende datastromen waaruit kan blijken of er witwaspraktijken en/of financiering van terroristische praktijken plaatsvindt. Switchlegal, in de persoon van Rob van den Hoven van Genderen, is de juridisch projectleider van Working Party 2 die als taak heeft de juridische kanten van het project te bewaken. Dit betreft met name de bewaking van de privacy bij het gebruik van de (persoons)gegevens zoals weergegeven in de doelstelling zoals hieronder omschreven.

Purpose

– To provide an overview of applicable laws and regulations;

– To analyze possible flaws and needs for the exchange of (personal) data

– To publish a set of instructions and guidelines for the ML fighters (FIUs, LEAs, banks, etc.) on the exchange and use of   data, data protection, privacy policies;

– To develop guidelines for the HEMOLIA system.

The Hemolia project

Hybrid Enhanced Money Laundering Intelligence, Investigation, Incrimination and Alerts (HEMOLIA) is a new generation Anti-Money Laundering (AML) intelligent multi-agent alert and investigation system which in addition to the traditional financial data makes extensive use of modern society’s huge telecom data source, thereby opening up a new dimension of capabilities to all money laundering fighters (FIUs, LEAs) and financial institutes (banks, insurance companies, etc.). Adding the telecom plane to the existing financial plane may improve and dramatically change AML doctrines, since another dimension is added to the analysis and investigation processes.

HEMOLIA, taking into account existing legal frameworks, will hybridize and correlate the financial and telecom planes in order to create richer and more accurate alerts, intelligence and investigation tools, as well as information sharing, both nationally and internationally. A major part of HEMOLIA will be the legal research and provision of legal guidelines to all ML-fighters. To respect privacy rights, HEMOLIA will bring a new model of push privacy preserving alerts where all FIUs and FIs are pushed with alerts that mark a transaction or customer with a money laundering/fraud risk level or risk probability, yet without disclosing any private data. This model may have outstanding impact on AML because it means that FIs will be alerted based on data of all other FIs and based on telecom service providers at the national and international level, opening up a new era of money Laundering and financial crime reporting by FIs to FIUs.

HEMOLIA will be tested in an environment which simulates live network and systems of 3 different countries which have implemented the HEMOLIA concept and which will cooperate to share AML-information.

Mission of the Project

The mission of the HEMOLIA consortium is to research and develop an innovative AML intelligent multi-agent alert and investigation system that will demonstrate the extensive benefits of fusing the telecom plane and financial plane for the sake of fighting financial crime, fraud and ML.

Even deployed in a very strict legal environment (from the point of view of access to financial/telecom data), HEMOLIA will represent an innovative approach and raise the level of ML activity detection by performing a deep analysis of the fused financial/telecom information.

Research Objectives

The research to be performed in HEMOLIA can be divided into 3 categories:

I. Technological objectives: The technological research will be based on the envisaged HEMOLIA architecture composed of two main parts:

(i) Data-collection and data-mining from the Financial Plane and from the Telecom Plane;

(ii) the HEMOLIA Core Modules which will analyse the Telecom Plane and Financial Plane Data Sources and will create enhanced alerts.

II. Legal framework of AML Systems: The legal research will include several areas:

(i) Telecom Plane Legal Framework and the “Financial Plane Legal Framework” for the different categories of end users (banks and financial institutes, FIUs/LEAs on the other hand) under the existing laws;

(ii) Content of the alerts;

(iii) Harmonization of the AML related data and boundaries (levels of permission) for access/use of the data by FI’s and LEA/FIUs.

III. AML end-users good practice and communication strategies including the definition of methodology and guidelines for an optimal use of the HEMOLIA system, information sparing methodologies between different authorities, at the national level and at the international level.

Work Plan

The HEMOLIA project is organized into 8 work packages (WPs); each with a set of deliverables and milestones. The WPs follow the logical phases of the implementation of the project and include consortium management and assessment of progress and results. The WPs have been identified with appropriate leaders and contributors reflecting the skill sets of the consortium. Each WP requires scientific collaboration between the participating partners and integration of their methods. Each WP will be led by the WP leader. WP leaders will monitor progress and ensure continuous communication and updating amongst all the partners. The management WP (WP0) will ensure the connectivity between the different WPs as illustrated in the pert chart (figure 3) and will be responsible for controlling the overall project.

WP 0 – Management, EY

WP1 – User & System Requirements: This WP will produce a representative set of requirements for HEMOLIA, based on input provided by consortium partners, end-users and analysts.

WP2 – EU AML Legal Framework Definition, VU Amsterdam University: The goal of this WP is to guide each step of the development of the HEMOLIA system in order to ensure that each developed component will be approved at the legal level, and to give a clear overview of the legal framework that will support the use of the HEMOLIA system in the pre-prosecution and prosecution process by LEA’s and other ML and terrorist fighters.

WP3 – System Architecture: This WP will develop a multi-tier architecture for the HEMOLIA system that supports a balanced approach of data integration and takes the legal framework into account as a design principle.

WP 4 – Analysis, Fusion, Indexing and Hybridisation: The goal of this WP is to develop the software components of layer-1 and layer-2 of the HEMOLIA framework and implement adequate algorithms for combining, analyzing and indexing data from different sources.

WP5 – Alerts Engine & GUI Investigation Tools: The aim of this WP is to develop the alerts engine for the financial plane and the characterisation of the AML suspects in the telecom plane. These two modules will be combined using the software developed in WP4.

WP6 – Integration & Validation: This WP will ensure smooth integration and validation of all HEMOLIA system components and layers into one consolidated framework.

WP7 – Field Testing: The field test WP led by FIUD will simulate a real national and international environment. The centralized deployment model will be simulated.

WP8 – Dissemination and Exploitation of Results: This WP will involve disseminating the findings of the project and building awareness amongst the AML and organised crime fighting communities (including end-users, governmental stakeholders and policy makers) as well as investigating the possibilities of further research or actual implementation and exploitation of these findings.

Partners

Partner Role in the project

Verint Systems Ltd., Israel Project coordinator. Leader of the integration and validation work. Leader for field testing of the HEMOLIA system.

Financial Investigation Unit (FIU), Denmark End user requirements and testing of the HEMOLIA system.

FIU.NET, Netherlands End user requirements and testing of the HEMOLIA system.

Grupo AIA, Spain Leader for the Alerts Engine&GUI Investigation Tools definition, development and implementation.

Cap Gemini, Netherlands Leader for the architecture research and definition work.

VU Amsterdam University, Netherlands Leader/coordinator for the EU AML Legal Framework research and Definition of the project.

SwitchLegal, Netherlands Executive leader/coordinator for the EU AML Legal Framework research and Definition of the project in cooperation with VU University

ZBP-Polish self government organization of banks, Poland Testing of HEMOLIA system and cooperation with University of Wroclaw in organization and providing HEMOLIA trainings.

University of Wroclaw, Poland Organization and providing HEMOLIA trainings.

Industrial Research Institute for Automation and Measurements – PIAP, Poland Expert knowledge on real demand for investigation tools and professional guidance in criminal network role, interactions and pattern indexing. Leader in HEMOLIA`s results dissemination.

Ernst & Young, Israel Administrative management

7 Framework Programme

Contract number: 261710

Budget: EUR 4 361 954

Project implementation period: May 2011 – April 2014

Coordinator: Verint Systems Ltd. Israel

Project web-site:  http://www.hemolia.eu

Contact person: Merel Dorgelo

Email: merel.dorgelo@switchlegal.nl

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“This project has received funding from the European Union’s Seventh Framework Programme for research, technological development and demonstration under grant agreement no 261710”

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